M&G Polymers USA, LLC v. Tackett

Whether under the Labor Management Relations Act (LMRA), courts should presume that silence as to the duration of retiree’s health-care benefits in collective bargaining agreements means the parties to the agreement intended those benefits to vest; or courts should require a statement that clearly states that the health care benefits survive the end of the agreement; or should there be at least some statement in the bargaining agreement that could support a ruling that the health care benefits should continue for life.

In December 2006, Petitioner announced that retirees would be required to contribute to the cost of their post-employment health care. At the time Respondents were participating in a for life retirement package in which the former employer paid all contributions to the health care plans.

Respondents brought three claims against Petitioner; first, violation of labor agreements under § 301 of the Labor Management Relations Act (LMRA); (2) violation of an employee welfare benefit plan under ERISA; and (3) breach of fiduciary duty under ERISA. The district court dismissed all three counts and Respondents appealed to the Court of Appeals for the Sixth Circuit where claim three was dismissed but claims one and two were reversed and remanded. A bench trial was held on the issue of liability where the district court issued an injunction. Petitioners appealed to the Sixth Circuit and Respondents appealed on the issue that the district courts order does not put Respondents back under the correct plan of pre-2007 Comprehensive Plan. The Court of Appeals for the Sixth Circuit ruled in favor of Respondents and affirmed the district court’s decision. Petitioner appeals to the Supreme Court of the United States.

Petitioner argues that certiorari must be granted to resolve this important issue that the courts are split on. The courts are split on how to construe collective bargaining agreements in retiree benefits cases and whether the same interpretive rules should apply to collective bargaining agreements and ERISA plans when determining when benefits have vested.