CHICAGO - A Seventh Circuit U.S. Court of Appeals panel on Jan. 24 affirmed the dismissal of an Employee Retirement Income Security Act class complaint filed against a railroad and a union following a change in representation and wage and benefits package (Teamsters Local Union No. 705, et al. v. Burlington Northern Santa Fe, LLC, et al., No. 11-3705, 7th Cir.; 2014 U.S. App. LEXIS 1476).