Allied Structural Steel Co. v. Spannaus 438 U.S. 234 (1978) Spannaus worked for Allied and was covered under their pension plan. The plan required workers to be employed for 15 years before they could collect anything upon retirement. Minnesota enacted the Private Pensions Benefits Protection Act, which said in part that if a company terminated an employee who'd worked for at least 10 years, they were responsible for paying the worker's pension benefits, regardless of what the employment contract said. Allied closed their office and fired Spannaus. Spannaus asked for his pension, but Allied refused because he'd been there less than 15 years. Spannaus sued. Allied argued that the Minnnesota law was a violation of their freedom of contract, and therefore a violation of the Contracts Clause of the Constitution. Article I §10 says, "No State shall pass any law impairing the obligation of contracts." The US Supreme Court found for Allied and overturned the Minnesota law. The Court used the same three part test they later annunciated in Energy Reserves Group Inc. v. Kansas Power and Light Co. (459 U.S. 400 (1983)), for determining if a law could survive under the Contracts Clause: Is there a substantial impairment of a contractual relationship? If so, does it serve a significant and legitimate public purpose? If so, does is reasonably related to achieving the goal? In this case, the Court found that the law caused a "substantial and severe" impact. However, the Court found that the law failed the second part of the test because it was not enacted "to deal with a broad, generalized economic, or social problem." The law regulated an area that had never been regulated before by the State, was not temporary, and was not narrowly tailored. So far, this has been the only time the US Supreme Court has invalidated a State Statute on Contracts Clause grounds since 1934.