Scarinci Hollenbeck, LLC, LLCScarinci Hollenbeck, LLC, LLC

Firm Insights

Retiree Health Benefits Discussed In The Supreme Court

Author: Scarinci Hollenbeck, LLC

Date: February 2, 2015

Key Contacts

Back

The U.S. Supreme Court recently ruled that courts should apply traditional contract principles to determine whether retiree health benefits survive the expiration of a collective bargaining agreement (CBA).

The decision in M&G Polymers v. Tackett expressly rejected the Sixth Circuit Court of Appeals’ long-standing decision in International Union, United Auto, Aerospace, & Agricultural Implement Workers of Am. v. Yard-Man, Inc., 716, F.2d 1476 (6th Cir. 1983) that retiree health benefits are presumed to vest for life unless the collective-bargaining agreement expressly provides otherwise..

The Facts of the Case

When M&G Polymers USA, LLC (M&G) purchased the Point Pleasant Polyester Plant in 2000, it entered into a CBA covering its union employees. The CBA provided that retirees, along with their surviving spouses and dependents, would “receive a full Company contribution towards the cost of [health care] benefits” and that such employee benefits would be provided “for the duration of [the] Agreement.” The agreement did not, however, address whether such retiree health care benefits would continue beyond the duration of the CBA.

Following the expiration of the CBA, M&G announced that it would require retirees to contribute to the cost of their health care benefits. Several retired employees sued M&G, claiming that the CBA created a vested right to continue receiving free health care benefits. On appeal and consistent with the Yard-Man precedent, the Sixth Circuit ruled in favor of the retirees.

The Supreme Court’s Decision

The Supreme Court found that, when a CBA fails to address the duration of retiree health benefits, a court should not presume that such benefits vest for life. Rather, the court should apply ordinary principles of contract law: “Courts should not construe ambiguous writings to create lifetime promises,” Justice Clarence Thomas wrote on behalf of the unanimous Court. He further added that “retiree health care benefits are not a form of deferred compensation.” 

According to the Court, the Sixth Circuit erred in relying on the Yard-Man decision because it rested upon principles that are incompatible with ordinary principles of contract law: “Yard-Man violates ordinary contract principles by placing a thumb on the scale in favor of vested retiree benefits in all collective-bargaining agreements. That rule has no basis in ordinary principles of contract law. And it distorts the attempt to ascertain the intention of the parties.”

The Message for Employers

The Supreme Court’s decision in M&G Polymers v. Tackett significantly changes retiree health care benefits expectations in both the private and public sectors, particularly regarding disputes involving existing agreements. While the decision arguably favors employers under current agreements, employers must be mindful to attend to the language of CBAs and other employment contracts, including those establishing ERISA plans, and expressly address whether retiree health care benefits intentionally vest for life.

No Aspect of the advertisement has been approved by the Supreme Court. Results may vary depending on your particular facts and legal circumstances.

Scarinci Hollenbeck, LLC, LLC

Related Posts

See all
A Simple Guide to Industry Roll-Up Acquisitions post image

A Simple Guide to Industry Roll-Up Acquisitions

When done successfully, industry roll-up acquisitions can dramatically grow and strengthen your business. In this post, we break down what an industry roll-up is, why companies pursue it, and what makes it an effective (and sometimes risky) business strategy. What Is an Industry Roll-Up Acquisition? In an industry roll-up acquisition of companies, a buyer acquires multiple companies […]

Author: Dan Brecher

Link to post with title - "A Simple Guide to Industry Roll-Up Acquisitions"
Genesis Mission: How the U.S. Government’s New AI Platform Will Reshape Corporate Innovation, Risk, and Competition post image

Genesis Mission: How the U.S. Government’s New AI Platform Will Reshape Corporate Innovation, Risk, and Competition

The federal government has launched one of the most ambitious scientific initiatives in decades, and it will redefine how companies develop technology, manage risk, and compete. The Genesis Mission, created by Executive Order and driven by the Department of Energy (“DOE”), is intended to accelerate scientific discovery through a national AI platform that links supercomputers, […]

Author: Michael J. Sheppeard

Link to post with title - "Genesis Mission: How the U.S. Government’s New AI Platform Will Reshape Corporate Innovation, Risk, and Competition"
Stablecoins and the GENIUS Act: How New Global Rules Are Reshaping Compliance post image

Stablecoins and the GENIUS Act: How New Global Rules Are Reshaping Compliance

Stablecoins Leave the Grey Zone Stablecoins were supposed to be the “boring” part of crypto: digital dollars that just work. Yet for years they have lived in a regulatory no-man’s-land, classified one day as securities, the next as commodities, and sometimes as something regulators had not even named yet. That uncertainty is finally starting to […]

Author: Bryce S. Robins

Link to post with title - "Stablecoins and the GENIUS Act: How New Global Rules Are Reshaping Compliance"
Don’t Overlook the Importance of Business License Management post image

Don’t Overlook the Importance of Business License Management

If you operate a business without the proper license, you risk fines, insurance issues, reputational harm, and even business closure. Even innocent mistakes, like forgetting to renew a license, can have significant consequences, such as losing your lawsuit for payment of services that are unlicensed, which makes it imperative to have business license management procedures […]

Author: Dan Brecher

Link to post with title - "Don’t Overlook the Importance of Business License Management"
Failing to Comply With NJ Rent Control Exemption May Prove Costly post image

Failing to Comply With NJ Rent Control Exemption May Prove Costly

What Developers Need to Know About New Jersey’s Rent Control Exemption Law to Ensure Entitlement to Exemption for Newly Constructed Multi-family Housing.  A property owner in Jersey City is facing a $400 million federal class action lawsuit alleging that the landlord did not follow the procedural steps required to be eligible for exemption from local […]

Author: Patrick T. Conlon

Link to post with title - "Failing to Comply With NJ Rent Control Exemption May Prove Costly"
Crypto Securities Law: When Tokens Become Investment Contracts post image

Crypto Securities Law: When Tokens Become Investment Contracts

The application of traditional federal securities laws to crypto assets continues to evolve. In some cases, the Securities and Exchange Commission (SEC) considers tokens and other digital assets to be securities. This makes them subject to federal securities law, including the Securities Act of 1933 and the Securities Exchange Act of 1934. This classification has […]

Author: Bryce S. Robins

Link to post with title - "Crypto Securities Law: When Tokens Become Investment Contracts"

No Aspect of the advertisement has been approved by the Supreme Court. Results may vary depending on your particular facts and legal circumstances.

Sign up to get the latest from our attorneys!

Explore What Matters Most to You.

Consider subscribing to our Firm Insights mailing list by clicking the button below so you can keep up to date with the firm`s latest articles covering various legal topics.

Stay informed and inspired with the latest updates, insights, and events from Scarinci Hollenbeck. Our resource library provides valuable content across a range of categories to keep you connected and ahead of the curve.

Let`s get in touch!

* The use of the Internet or this form for communication with the firm or any individual member of the firm does not establish an attorney-client relationship. Confidential or time-sensitive information should not be sent through this form. By providing a telephone number and submitting this form you are consenting to be contacted by SMS text message. Message & data rates may apply. Message frequency may vary. You can reply STOP to opt-out of further messaging.

Sign up to get the latest from the Scarinci Hollenbeck, LLC attorneys!