NEW YORK - A pension plan did not violate the Employee Retirement Income Security Act when it awarded pension credits based on a 200-day work year for years in which participants worked less than full time, where the plan did not define "year of participation" but previous years' plans defined it as 200 days, the Second Circuit U.S. Court of Appeals affirmed in a summary order on July 3 (Kenneth Kammerer, et al. v. The Motion Picture Industry Pension Plan, et al., No. 11-2422, 2nd Cir.; 2012 U.S. App. LEXIS 13541).