In the case of Curtiss-Wright Corporation v. Frank C. Schoonejongen, et al., 1994, the U.S. Supreme Court was asked to determine whether an employer's reservation of rights in a health benefits plan allowed it to unilaterally modify or terminate retiree medical benefits without violating the Employee Retirement Income Security Act (ERISA). The court ruled that ERISA does not prohibit such modifications if they are clearly stated in the plan documents and do not violate other provisions of law. However, any changes must be communicated to employees and retirees through a Summary Plan Description (SPD) as required by ERISA regulations. In this particular case, Curtiss-Wright had reserved its right to amend its healthcare plans but failed to properly communicate these changes via SPDs which led lower courts ruling against them initially before being overturned by Supreme Court decision.

The dissenting opinion in the Curtiss-Wright Corporation v. Frank C. Schoonejongen case, delivered by Justice Stevens, argued that the majority's decision was based on an incorrect interpretation of ERISA (Employee Retirement Income Security Act). The majority held that a company could unilaterally modify or terminate its employees' welfare benefits plan without violating ERISA as long as it reserved this right in the plan document. However, Justice Stevens contended that such unilateral changes should be considered amendments to the original plan and thus subject to certain procedural requirements under ERISA. He also disagreed with the majority's view that a reservation of rights clause need not specify how modifications will be made; he believed this lack of specificity would lead to uncertainty and potential disputes over what constitutes valid modification procedures.