CNH Industrial N. v. v. Reese, 138 S. Ct. 761

CNH and its union executed a 1998 collective-bargaining agreement that provided retiree health benefits to employees who "retire under the Pension Plan" and stated that the group benefit plan ran concurrently with the CBA.
The 1998 CBA contained a general durational clause setting termination in May 2004 and a clause disposing of "any and all bargaining issues."
After the agreement expired, a class of retirees sued seeking a declaration that health benefits had vested for life and an injunction against CNH’s changes.
The district court initially granted summary judgment to CNH, then on reconsideration awarded summary judgment to the retirees after this Court’s decision in M&G Polymers v. Tackett.
The Sixth Circuit affirmed in part, finding the CBA ambiguous (relying on Yard-Man–style inferences) and therefore permitting extrinsic evidence, which supported lifetime vesting; Judge Sutton dissented.
The Supreme Court granted certiorari and reversed, holding the Sixth Circuit’s reliance on Yard-Man inferences and use of them to create ambiguity conflicted with Tackett and ordinary contract principles.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Yard-Man inferences can be used to render a CBA ambiguous and permit extrinsic evidence about lifetime vesting	Yardiffs: Yard-Man inferences show the CBA could reasonably be read to vest lifetime benefits, so ambiguity permits extrinsic evidence	CNH: Tackett forbids Yard-Man inferences; absent explicit terms, the durational clause controls and the CBA is unambiguous	The Court held Yard-Man inferences are not ordinary contract principles and cannot be used to manufacture ambiguity; they were rejected in Tackett
Whether the 1998 CBA vested lifetime retiree health benefits	Retirees: silence on duration + specific carve-outs and tying to pension eligibility support a reasonable reading of lifetime vesting	CNH: general durational clause and statement that benefits run concurrently show benefits expired with the CBA	The Court held the only reasonable interpretation is that health benefits expired with the CBA; no lifetime vesting absent an explicit promise

M&G Polymers USA, LLC v. Tackett, 574 U.S. (2015) (collective-bargaining agreements must be interpreted under ordinary contract principles; rejected Yard-Man inferences)
International Union, United Auto, Aerospace & Agricultural Implement Workers of Am. v. Yard-Man, Inc., 716 F.2d 1476 (6th Cir. 1983) (origin of inferences presuming lifetime vesting)
Textile Workers v. Lincoln Mills of Ala., 353 U.S. 448 (1957) (agreements interpreted according to ordinary contract law)
Litton Financial Printing Div., Litton Business Systems, Inc. v. NLRB, 501 U.S. 190 (1991) (contractual obligations ordinarily cease upon termination of the agreement)
Sprague v. General Motors Corp., 133 F.3d 388 (6th Cir. 1998) (applied ordinary contract principles in noncollective-contract context)