In the case of Guidry v. Sheet Metal Workers National Pension Fund et al., 1989, Lionel Guidry, a union official was found guilty of embezzling funds from his employer and ordered to make restitution as part of his criminal sentence. The issue before the Supreme Court was whether federal law permitted an exception to anti-alienation provisions in pension plans covered by ERISA (Employee Retirement Income Security Act) for cases involving equitable or constructive trusts or other similar remedies. The court ruled unanimously that such exceptions were not permissible under ERISA's strict rules against alienation of pension benefits, even in situations where the beneficiary had been convicted of stealing from their employer. This decision upheld ERISA’s primary purpose which is to protect workers' retirement savings and ensure they receive their promised benefits regardless of other legal claims against them.

In the dissenting opinion for Guidry v. Sheet Metal Workers National Pension Fund et al., Justice Blackmun, joined by Chief Justice Rehnquist and Justices O'Connor and Scalia, argued that the majority's decision to not allow an offset of pension benefits was inconsistent with previous rulings. They contended that while ERISA generally prohibits assignment or alienation of pension funds, it does not explicitly prohibit offsets in cases where a fiduciary has misappropriated those funds. The dissenting justices believed that allowing such an offset would serve as a deterrent against future misconduct by fiduciaries without undermining the primary purpose of ERISA - to protect workers' retirement security. Furthermore, they pointed out that denying this remedy could potentially leave victims without any means to recover their losses if other assets are insufficient or unavailable.