former reserve employees in United Steelworkers, and because the Trustee’s claims mirror the claims brought by the non-settling former reserve employees in Warner. The PBGC and Ricke argue that only the Section 4049 Trustee may maintain an action for unfunded non-guaranteed pension benefits under SEPPAA, and that the releases signed in connection with the settlement of United Steelworkers are, therefore, invalid. As ERISA has evolved, an individual’s right to sue for unfunded non-guaranteed pension benefits has gone through a series of transformations. Before the passage of SEPPAA, courts had determined that individuals could bring actions for such benefits. See Murphy v. Heppenstall Co., 635 F.2d 233, 233 (3d Cir.1980), cert. denied, 454 U.S. 1142, 102 S.Ct. 999, 71 L.Ed.2d 293 (1982) (<HOLDING>); accord United Steelworkers of Am. v. North
holding that it is not inconsistent with the statutory scheme to permit employees to recover directly from the employer nonguaranteed pension benefits   holding that although disability benefits cannot be included as part of the marital estate a court may consider the waiver of retirement pension benefits in favor of disability benefits in determining whether there has been a material change in circumstances which would justify modification of an alimony award to a former spouse who was previously awarded a fixed percentage of the retirement pension benefits holding that an employees protected interest in a pension vested before he or she became eligible to collect the pension holding that an antiassignment clause in a pension plan is valid under  541c2 and that the pension benefits thus do not become property of the estate and may not be made subject to a pay order under section 1325c holding that the defendant withheld pension benefits in breach of the plan