Retiree Health Care Benefits

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Several retired employees of Dominion Energy Transmission, Inc. sued their former employer alleging that they were entitled to lifetime healthcare benefits, and the unilateral changes made by Dominion to their post-retirement medical benefits violated ERISA.  The Third Circuit concluded that the retirees failed to state a claim.  Applying ordinary principles of contract interpretation, the Court…

In an opinion released yesterday, the Supreme Court reaffirmed that collective bargaining agreements (CBAs) must be interpreted according to “ordinary principles of contract law.” CNH Industrial N.V. v. Reese, No. 17-515, 2018 WL 942419 (U.S. Feb. 20, 2018).  In so ruling, the Court again rejected the Sixth Circuit’s inference from silence that CBAs vested…

The Third Circuit rejected a claim for lifetime health insurance benefits filed by retired employees of Johnson Controls, finding that the clear and unambiguous language of the CBAs and group insurance booklets did not guarantee lifetime health insurance benefits. The suit was filed after the group insurance booklets, which were incorporated into and subject to…

In three decisions issued on the same day, the Sixth Circuit held that Meritor retirees were not entitled to lifetime health benefits, while retirees at Kelsey-Hayes and CNH Industries were entitled to contractually vested health benefits. In the first case, a group of former Meritor employees filed suit after the company reduced their healthcare benefits. …

The Fourth Circuit upheld an employer’s unilateral decision to amend a collective bargaining agreement to cap employer contributions to retiree health benefits and freeze Medicare reimbursements for hourly retirees. In so ruling, the Court applied general contract principles, as required by the Supreme Court’s decision in M&G Polymers USA, LLC v. Tackett, 135 S.…

A federal district court in Ohio dismissed retirees’ claims for lifetime healthcare benefits from Honeywell.  Honeywell provided healthcare benefits to plaintiffs through a series of collective bargaining agreements and, although it continued to do so for several years after the final CBA expired, Honeywell eventually notified plaintiffs that it would terminate contributions toward their healthcare…

A federal district court in Michigan dismissed retirees’ claims for lifetime, unalterable healthcare benefits from BorgWarner.  BorgWarner provided healthcare benefits to Plaintiffs through a series of collective bargaining agreements  and health insurance agreements.  After BorgWarner unilaterally modified the available retiree healthcare benefits, Plaintiffs filed suit.  Applying the principles set forth in M&G Polymers USA, LLC…

The Sixth Circuit ruled that retirees of Moen Inc. were not entitled to lifetime health benefits upon finding that an underlying collective bargaining agreement (CBA) did not create vested rights to these benefits.  Moen and its predecessor were parties to several CBAs with a local affiliate of the International Union, United Automobile, Aerospace and Agricultural…

On remand from the Supreme Court, the Sixth Circuit sent the parties in Tackett v. M&G Polymers USA, LLC back to the district court for additional factual determinations on whether the retirees who commenced the lawsuit had vested in their health benefits.

Nearly a decade ago, a class of retirees sued their former employer’s successor, M&G Polymers, after it announced that it would begin requiring the retirees to contribute toward their health benefits.  The district court granted M&G Polymer’s motion to dismiss and held that the CBA clearly did not give the retirees a vested right to health benefits.  On appeal, the Sixth Circuit reversed; applying the principles it established more than three decades earlier in UAW v. Yard-Man, Inc., 716 F.2d 1476 (6th Cir. 1983), it held that the retirees had stated a plausible claim.  The district court subsequently ruled in favor of the retirees on remand, and the Sixth Circuit affirmed.