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
Tackett
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.