The U.S. Supreme Court case Laborers Health and Welfare Trust Fund for Northern California et al. v. Advanced Lightweight Concrete Co., Inc., 1987, revolved around the issue of whether an employer who withdraws from a multiemployer pension plan is liable for withdrawal liability under the Multiemployer Pension Plan Amendments Act (MPPAA) of 1980 if they had ceased making contributions before MPPAA was enacted but were still obligated to contribute under their collective bargaining agreement when it came into effect. The court ruled in favor of Laborers Health and Welfare Trust Fund, stating that employers are indeed subject to this liability even if they stopped contributing prior to MPPAA's enactment as long as they remained obligated by their contract at its inception date.

In the dissenting opinion for the case of Laborers Health and Welfare Trust Fund for Northern California et al. v. Advanced Lightweight Concrete Co., Inc., Justice Blackmun argued that ERISA (Employee Retirement Income Security Act) was designed to protect employees' pension rights, not to shield employers from state law claims. He contended that the majority's interpretation of complete preemption under Section 502(a) of ERISA was overly broad and inconsistent with congressional intent. According to him, Congress did not intend for ERISA to preempt all state laws related or connected with employee benefit plans but only those that directly regulate them or conflict with its provisions. Therefore, he believed that a construction company’s debt owed due to unpaid contributions should be recoverable under state law since it does not interfere with national uniformity in plan administration nor does it pose any threat to federal interests protected by ERISA.