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M&G Polymers USA v. Tackett, 13-1010

In this case, plaintiff retired employees sued defendant, their former employer, asserting that certain expired collective-bargaining agreements created a right to lifetime contribution-free healthcare benefits for retirees, their surviving spouses, and their dependents. The Sixth Circuit sided with the retirees, arguing under International Union, United Auto, Aerospace & Agricultural Implement Workers of Am. v. Yard-Man, Inc. that retiree healthcare benefits are unlikely to be left up to future negotiations. The judgment of the Sixth Circuit is vacated and the case is remanded, where Yard-Man inferences are inconsistent with ordinary principles of contract law, given that: 1) retiree healthcare benefits are not a form of deferred compensation; 2) requiring a contract to include a specific durational clause for retiree healthcare benefits to prevent vesting conflicts with the principle of contract law that the written agreement is presumed to encompass the whole agreement of the parties; and 3) when a contract is silent as to the duration of retiree benefits, a court may not infer that the parties intended those benefits to vest for life.

Appellate Information

  • Decided 01/26/2015
  • Published 01/26/2015

Judges

  • Thomas

Court

  • United States Supreme Court

Counsel

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