NEW ORLEANS - The Fifth Circuit U.S. Court of Appeals on Aug. 27 ruled 2-1 that former employees' deferred compensation arrangements did not constitute Employee Retirement Income Security Act-governed plans because they did not require "an ongoing administrative scheme" (Carol A. Cantrell, et al. v. Briggs & Veselka Company v. Cantrell & Cowen, P.L.L.C., No. 12-20294, 5th Cir.; 2013 U.S. App. LEXIS 17922).