SAN FRANCISCO - The administrator of a plan governed by the Employee Retirement Income Security Act (ERISA), 29 U.S.C.S. § 1001 et seq.,did not abuse its discretion by interpreting the plan's provision that disability benefits would be reduced by pension benefits "received" to include amounts rolled over into an individual retirement account (IRA), the Ninth Circuit U.S. Court of Appeals affirmed July 3 (David Day v. AT&T Disability Income Plan, No. 10-16479, 9th Cir.; 2012 U.S. App. LEXIS 13558).