WASHINGTON, D.C. - The U.S. Supreme Court on April 16 declined to review a Seventh Circuit U.S. Court of Appeals opinion ruling that retirement plans that failed to use whipsaw calculations in calculating lump-sum payments to participants who received early retirement benefits were not entitled to deference as to the method of calculating the participants' recovery and that the participants' claims accrued when they received their lump-sum distributions (James Barberis, et al. v. Retirement Plan for Employees of S.C. Johnson & Son, Inc., et al., No. 11-843, U.S. Sup.; Retirement Plan for Employees of S.C. Johnson & Son, Inc., et al. v. James Barberis, et al., No. 11-970, U.S. Sup.).