Barton v. Constellium Rolled Products-Ravenswood, LLC
2017 U.S. App. LEXIS 5087
| 4th Cir. | 2017Background
- Constellium Rolled Products–Ravenswood (employer) provided retiree health benefits under Article 15 of successive CBAs with the United Steelworkers (1988–2010 CBAs); the 2010 CBA expired July 15, 2012.
- Article 15 and the Retired Employees’ Group Insurance Program SPD repeatedly state benefits remain "for the term of the Labor Agreement."
- Separate "Cap Letters" (2002, 2005, 2010) set employer contribution caps and anticipated cost-sharing; some caps were scheduled to take effect after CBA expiration, others before.
- In Jan 2013 Constellium unilaterally reduced retiree health contributions and froze Medicare Part B reimbursements; retirees and the Union sued alleging vesting.
- District court granted summary judgment for Constellium; Fourth Circuit reviews de novo and affirms, applying ordinary contract principles post-Tackett.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether retiree health benefits vested beyond CBA term | Retirees: provisions (Article 15 + SPD + Cap Letters + other SPD language) show intent to vest life-long benefits | Constellium: Article 15 and SPD unambiguously limit benefits "for the term of" the CBA; Cap Letters and other provisions permit modification | Benefits did not vest: unambiguous durational language controls and forecloses vesting absent a clear signal |
| Whether Cap Letters create a post-termination entitlement | Retirees: post-termination effective dates and cost-allocation mechanism imply continuation after CBA | Constellium: Cap Letters show parties expected to bargain and modify benefits; some caps were precautionary and adjustable | Cap Letters do not overcome Article 15’s durational language and do not show clear intent to vest |
| Whether other SPD clauses (dependents, surviving spouses, Medicare Part B) indicate vesting | Retirees: those clauses imply lifetime coverage or continuity beyond CBA | Constellium: clauses include temporal limits tied to CBA term or eligibility, and do not express vesting | Clauses are consistent with duration-limited benefits and do not demonstrate vesting |
| Whether pre-Tackett cases (Quesenberry, Keffer) control | Retirees: prior Fourth Circuit rulings support reading clauses in context to find vesting | Constellium: Tackett displaced Yard-Man presumption; prior cases are distinguishable on facts | Tackett governs; prior cases do not compel vesting here because Article 15’s durational language is unambiguous |
Key Cases Cited
- M&G Polymers USA, LLC v. Tackett, 135 S. Ct. 926 (2015) (courts must apply ordinary contract principles; no presumption of vesting when contract is silent)
- International Union v. Yard-Man, 716 F.2d 1476 (6th Cir. 1983) (pre-Tackett presumption that retiree benefits vest absent clear contrary evidence)
- Litton Fin. Printing Div. v. NLRB, 501 U.S. 190 (1991) (contractual obligations ordinarily cease on termination of the bargaining agreement)
- Dewhurst v. Century Aluminum Co., 649 F.3d 287 (4th Cir. 2011) (contrast between pension vesting language and health-benefit language informs intent)
- Quesenberry v. Volvo Trucks N. Am. Retiree Healthcare Benefit Plan, 651 F.3d 437 (4th Cir. 2011) (interpreting cost-overrun/trust provisions may require benefits to continue past CBA term)
- Keffer v. H.K. Porter Co., 872 F.2d 60 (4th Cir. 1989) (vesting found where CBA tied retiree benefits to a post-termination event)
- Trumball Invs. Ltd. I v. Wachovia Bank, N.A., 436 F.3d 443 (4th Cir. 2006) (use of unambiguous language in one contract section shows parties knew how to manifest vesting intent)