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M&G Polymers USA v. Tackett

United States Supreme Court

135 S.Ct. 926 (2015)

Relevant factsFree

M&G Polymers (defendant) and its union entered a collective bargaining agreement (CBA) and companion Pension, Insurance, and Service Award Agreement (P&I) stating retirees 'will receive full Company contribution towards the cost of' healthcare benefits, but when the agreements were renewed, M&G began requiring retiree contributions instead. Retirees led by Hobert Tackett (plaintiffs) sued, claiming M&G had promised lifetime, contribution-free healthcare; the district court dismissed for failure to state a claim, but the court of appeals reversed, relying on the Sixth Circuit's Yard-Man precedent to read 'will receive' as showing intent to vest lifetime benefits, and on remand the district court permanently enjoined M&G from requiring contributions. The court of appeals affirmed, and the Supreme Court granted certiorari.

IssueFree

Whether, when a collective bargaining agreement is silent regarding the duration of healthcare benefits, a court must apply ordinary contract principles to determine that duration rather than inferring lifetime vesting.

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