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
New Jersey Will Contest Grounds Explained post image

New Jersey Will Contest Grounds Explained

How Courts Evaluate Testamentary Capacity and Undue Influence Will contests in New Jersey are difficult to win, given the strong presumption that a properly executed will reflects the testator’s intent. However, challenges based on lack of testamentary capacity and undue influence remain common, particularly where there are concerns about mental capacity or the involvement of […]

Author: Marc J. Comer

Link to post with title - "New Jersey Will Contest Grounds Explained"
Legal Issues Before Bringing on Investors post image

Legal Issues Before Bringing on Investors

Bringing on outside investors can provide the capital and strategic support a business needs to grow. However, raising capital also introduces important legal, financial, and operational considerations. Before bringing on investors, businesses should address key legal issues to reduce risk, streamline investor due diligence, and position the company for long-term success. Early preparation signals that […]

Author: Dan Brecher

Link to post with title - "Legal Issues Before Bringing on Investors"
SECURE 2.0 RMD Planning Strategies post image

SECURE 2.0 RMD Planning Strategies

How the Updated Law Shapes Retirement and Estate Planning The SECURE 2.0 Act of 2022 materially reshapes the required minimum distribution (RMD) landscape, extending tax deferral opportunities while accelerating distribution requirements for many beneficiaries. For high-net-worth individuals and families, these changes are not merely technical. They require a reassessment of retirement income strategies, beneficiary planning, […]

Author: Marc J. Comer

Link to post with title - "SECURE 2.0 RMD Planning Strategies"
Buying Commercial Property in New Jersey: Legal Guide for Small Businesses post image

Buying Commercial Property in New Jersey: Legal Guide for Small Businesses

Small businesses considering buying commercial property in New Jersey must evaluate a range of legal, financial, and operational factors. While ownership can offer long-term value and control, it also introduces significant risks if not properly structured. This guide outlines key considerations to help New Jersey business owners make informed decisions, minimize legal exposure, and successfully […]

Author: Robert L. Baker, Jr.

Link to post with title - "Buying Commercial Property in New Jersey: Legal Guide for Small Businesses"
The SEC’s Latest Guidance on Applying Federal Securities Laws to Tokenized Securities post image

The SEC’s Latest Guidance on Applying Federal Securities Laws to Tokenized Securities

On January 28, 2026, staff of the U.S. Securities and Exchange Commission’s Divisions of Corporation Finance, Investment Management, and Trading and Markets issued a joint statement clarifying how existing federal securities laws apply to tokenized securities. The SEC’s “Statement on Tokenized Securities” does not establish new law, but it does provide greater clarity on the […]

Author: Dan Brecher

Link to post with title - "The SEC’s Latest Guidance on Applying Federal Securities Laws to Tokenized Securities"
Common Legal Mistakes NYC and New Jersey Business Owners Make post image

Common Legal Mistakes NYC and New Jersey Business Owners Make

Operating a business in the New Jersey and New York City metropolitan region offers incredible opportunities, but it also requires navigating a dense and highly regulated legal environment. From entity formation to regulatory compliance, seemingly minor legal oversights can expose business owners to significant risk. In our work with businesses throughout the region, our attorneys […]

Author: Dan Brecher

Link to post with title - "Common Legal Mistakes NYC and New Jersey Business Owners Make"

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!