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
Tackett
Sixth Circuit Issues Trilogy on Retiree Health Benefits
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. …
Fourth Circuit Rejects Retirees’ Claim for Vested Health 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.…
Honeywell Defeats Retirees’ Class Action Suit for Lifetime Health Benefits
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…
District Court Rejects Retirees’ Claim for Lifetime Healthcare Benefits
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…
District Court Rules Johnson Controls Retirees Not Entitled to Lifetime Health Benefits
A district court in the Middle District of Pennsylvania held that, notwithstanding the Supreme Court’s decision in M & G Polymers USA, LLC v. Tackett, 135 S. Ct. 926 (2015), the Third Circuit’s rule that clear and express language was required for health benefits to vest was still good law. On that basis, it…
Sixth Circuit Rules that Employer Can Terminate Retiree Health Benefits
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…
Retiree Health Benefits Case Remanded to District Court for Additional Fact Finding
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.
Another Post-Tackett Ruling Denying Retiree Health Benefits
A district court in West Virginia recently held that retirees were not entitled to lifetime health benefits under the clear and unambiguous language of the relevant collective bargaining agreements. Shortly after Constellium modified retiree health benefits to provide less favorable coverage, the retirees sued, alleging that they had a vested right to the prior level…
Supreme Court Announces “Wipe-Out” of Yard-Man Presumption in Advance of Storm
With storm clouds threatening in the northeast, the Supreme Court cast a ray of sunlight for employers today by rejecting the use of a problematic inference in adjudicating claims for retiree benefits brought pursuant to collective bargaining agreements.