Arbuckle v. General Motors LLC, 499 Mich. 521

Background

Clifton Arbuckle retired from General Motors (GM) in May 1993 and received a disability pension and workers’ compensation benefits for a 1991 work-related back injury; he later received SSDI.
A 1990 GM–UAW letter of agreement (incorporated into the 1990 CBA) prohibited coordinating disability pension benefits with workers’ compensation “until termination or earlier amendment of the 1990 Collective Bargaining Agreement.”
Subsequent CBAs from the 1990s through 2007 contained similar durational language; a 2007 letter permitted coordination for retirees injured/retiring on or after Oct. 1, 2007.
In 2009 GM and the UAW amended the 2007 arrangement (incorporated into the 2009 CBA) to apply the coordination formula to “all retirees who retired prior to January 1, 2010,” and GM notified Arbuckle that his WC benefits would be reduced effective Jan. 1, 2010.
Administrative tribunals reached conflicting results; the MCAC allowed coordination, the Court of Appeals reversed, and the Michigan Supreme Court granted review to decide preemption and whether Arbuckle’s right to noncoordination was vested.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Arbuckle’s state-law claim is preempted by §301 LMRA	Arbuckle framed the claim as enforcement of statutory WDCA rights (state law) not requiring CBA interpretation	GM argued resolution requires interpretation of the CBA and postretirement amendments, so §301 preemption applies	§301 preempts: deciding coordination requires interpreting CBAs; federal law governs
Whether Arbuckle had a vested right to uncoordinated benefits under the 1990 agreement	Arbuckle: as a retiree he was not bound by later CBAs; the 1990 prohibition against coordination remained in effect absent his consent	GM: 1990 letter limited noncoordination to the term of the CBA (‘‘until termination or earlier amendment’’), so later agreements could permit coordination	No vesting: the 1990 agreement’s durational language shows benefits were nonvested and subject to modification
Whether postretirement CBA amendments (2007/2009) could lawfully authorize coordination of Arbuckle’s benefits	Arbuckle: UAW had no authority to bind retirees; postretirement changes cannot strip his uncoordinated benefits	GM: subsequent letters (2007/2009) expressly expanded coordination, and nonvested retiree benefits are modifiable through collective bargaining	Held for GM: later agreements could apply; coordination authorized under federal law analysis
Whether SSDI may be used to offset WC benefits under MCL 418.354(11)	Arbuckle argued statute forbids using SSDI to reduce WC benefits absent a federal amendment	GM raised defenses but court considered the issue inadequately briefed by Arbuckle	Court declined to decide the SSDI-specific statutory question (abandoned on appeal)

Key Cases Cited

M&G Polymers USA, LLC v. Tackett, 574 U.S. _ (2015) (courts should not infer lifetime vesting of retiree benefits from silence; ordinary contract principles govern CBA interpretation)
United Steelworkers of Am. v. Rawson, 495 U.S. 362 (1990) (§301 requires federal law to govern interpretation and application of CBAs)
Jones v. Gen. Motors Corp., 939 F.2d 380 (6th Cir.) (state-law claims are preempted under §301 when resolution requires interpreting a CBA)
Garbinski v. Gen. Motors LLC, [citation="521 F. App'x 549"] (6th Cir. 2013) (letter agreement with express durational language did not create vested uncoordinated-benefit rights)
Allis-Chalmers Corp. v. Lueck, 471 U.S. 202 (1985) (state-law claims that require interpretation of CBAs are preempted by §301)