SPOKANE, Wash. - An underfunded multiemployer pension plan that adopted a rehabilitation plan eliminating subsidized early retirement benefits pursuant to the Pension Protection Act (PPA) did not violate the Fifth Amendment of the U.S. Constitution, a federal judge in Washington ruled May 2 (Gerald C. Arendt, et al. v. Washington-Idaho-Montana Carpenters-Employers Retirement Trust Fund, et al., No. CV-11-5135, E.D. Wash.; 2014 U.S. Dist. LEXIS 62061).