Employers who participate in underfunded multiemployer pension plans should be aware of two recent court cases that could affect their withdrawal liability. On May 21, 2026, the United States Supreme Court issued its unanimous decision in M & K Employee Solutions, LLC v. Trustees of the IAM National Pension Fund and August 1, 2025, the Eleventh Circuit court issued a decision in Perfection Bakeries Inc. v. Retail Wholesale & Dept. Store International Union.