Barton v. Constellium Rolled Products-Ravenswood, LLC
856 F.3d 348
4th Cir.2017Background
- Constellium Rolled Products–Ravenswood (employer) operated an aluminum plant represented by the United Steelworkers; several employees retired under seven successive CBAs (1988–2010).
- Each CBA’s Article 15 incorporated a retiree health insurance "Retired Employees’ Group Insurance Program" booklet (SPD) and stated benefits would remain "for the term of the . . . Labor Agreement."
- Separate "Cap Letters" (2002, 2005, 2010) set employer contribution caps and contemplated cost-sharing and future bargaining over caps; some caps were timed to take effect after a CBA’s expiration, others before expiration.
- In 2012–2013, during bargaining, Constellium unilaterally limited contributions and froze Medicare Part B reimbursements; retirees and the union sued claiming the retiree health benefits had vested.
- The district court granted summary judgment to Constellium; the Fourth Circuit affirmed, holding the CBA/SPD’s durational language unambiguously precluded vesting.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether retiree health benefits vested beyond CBA term | Retirees: wording elsewhere (Cap Letters, SPDs, dependent/surviving-spouse language, past practice) shows intent to vest benefits after CBA expiration | Constellium: Article 15 and SPD explicitly limit benefits "for the term of" the CBA; Tackett requires clear, unambiguous vesting language | Held for Constellium: durational language is unambiguous; benefits do not vest |
| Whether Cap Letters show intent to vest benefits | Cap Letters’ post-termination effective dates and cost-sharing show parties expected benefits to survive CBA end | Cap Letters themselves modify benefits, provide bargaining flexibility, and some start before expiration—so they do not establish vesting | Held: Cap Letters do not overcome Article 15’s durational language |
| Whether other SPD provisions (dependents, surviving spouses, Medicare Part B) create vesting | Retirees: provisions referring to death, surviving spouse benefits, and Medicare reimbursement imply lifetime or post-CBA continuation | Constellium: those provisions either define beneficiary classes or expressly limit benefits to duration of the Labor Agreement | Held: these SPD provisions do not negate the clear durational limitation |
| Whether pre-Tackett precedents (Quesenberry, Keffer) control | Retirees: prior Fourth Circuit decisions support inferring vesting in similar contexts | Constellium: Tackett changed the legal framework—courts must apply ordinary contract principles and not infer vesting absent clear language | Held: Tackett controls; Quesenberry and Keffer are distinguishable or superseded in application here |
Key Cases Cited
- M&G Polymers USA, LLC v. Tackett, 135 S. Ct. 926 (2015) (courts must apply ordinary contract law to CBAs; cannot infer vesting when contract is silent)
- Yard-Man, Inc. v. International Union, United Automobile, Aerospace & Agricultural Implement Workers, 716 F.2d 1476 (6th Cir. 1983) (prior presumption of vesting criticized by Tackett)
- Litton Financial Printing Div., Litton Business Systems, Inc. v. NLRB, 501 U.S. 190 (1991) (contractual obligations ordinarily cease upon termination of bargaining agreement)
- Dewhurst v. Century Aluminum Co., 649 F.3d 287 (4th Cir. 2011) (contrast between pension vesting language and health-benefit language is probative of intent)
- Quesenberry v. Volvo Trucks N. Am. Retiree Healthcare Benefit Plan, 651 F.3d 437 (4th Cir. 2011) (cost-overrun/trust-fund structure previously supported finding that certain health obligations extended past CBA)
- Keffer v. H.K. Porter Co., 872 F.2d 60 (4th Cir. 1989) (benefits explicitly tied to post-termination event—Medicare eligibility—supported vesting)