Hobert Tackett v. M&G Polymers USA, LLC
811 F.3d 204
| 6th Cir. | 2016Background
- Retirees from an M&G Polymers plant sued claiming their collective bargaining agreements (CBAs) and associated Pension & Insurance agreements (P&I) promised lifetime, contribution-free retiree health care; M&G began requiring retiree contributions in 2006.
- Lower district court initially dismissed the complaint (Tackett 2007), relying in part on cap letters; on further proceedings the court found benefits vested and enjoined M&G from requiring contributions.
- This court (Tackett I and Tackett II) had applied Yard‑Man’s interpretive framework, inferring vesting from CBA language (e.g., “full Company contribution”) and contextual factors.
- The Supreme Court in M&G Polymers v. Tackett vacated Tackett II and abrogated Yard‑Man, instructing courts to apply "ordinary principles of contract law" when deciding whether retiree benefits vest.
- On remand, the Sixth Circuit held that prior factual findings were made under the “shadow of Yard‑Man,” remanded to the district court to (1) determine what documents form the parties’ agreements (including whether cap letters are part of the contract or admissible extrinsic evidence), (2) decide whether extrinsic evidence may be considered, and (3) determine under ordinary contract principles whether retiree benefits vested.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Agreements vest lifetime, contribution-free retiree health benefits | Agreements’ language (e.g., “full Company contribution”) and linkage to pension benefits show intent to vest | General durational silence and cap letters show employer never promised unlimited, contribution-free benefits | Remanded: court must decide under ordinary contract principles whether vesting occurred (no presumption either way) |
| Whether cap letters are part of the Agreements or admissible extrinsic evidence | Cap letters do not apply to retirees; should not defeat vesting finding | Cap letters are part of the agreement or show parties’ intent that contributions be capped | Remanded for district court to make factual determination whether cap letters are contract terms or admissible extrinsic evidence |
| Proper interpretive standard: Yard‑Man inferences vs. ordinary contract law | Yard‑Man supported inferring vesting from context and labor policy | Yard‑Man gave a pro‑employee tilt and is inconsistent with ordinary contract principles | Yard‑Man abrogated by Supreme Court; apply ordinary principles of contract law without a ‘‘thumb on the scale’’ |
| Use of extrinsic evidence (bargaining history, industry custom) to resolve ambiguity | Extrinsic evidence (bargaining history, trial evidence) may show intent to vest | Employer contested inclusion and relevance of extrinsic materials (and cap letters) | District court should determine admissibility and weight of extrinsic evidence under ordinary contract rules on remand |
Key Cases Cited
- M&G Polymers USA, LLC v. Tackett, 135 S. Ct. 926 (2015) (Supreme Court: abrogated Yard‑Man; directed use of ordinary contract principles to decide vesting)
- Yard‑Man, Inc. v. United Auto., Aerospace, & Agric. Implement Workers, 716 F.2d 1476 (6th Cir. 1983) (established interpretive framework favoring vesting; abrogated by M&G Polymers)
- Tackett v. M&G Polymers USA, LLC, 561 F.3d 478 (6th Cir. 2009) (appellate decision applying Yard‑Man to infer vesting)
- Tackett v. M&G Polymers USA, LLC, 733 F.3d 589 (6th Cir. 2013) (Tackett II; affirmed vesting under Yard‑Man; vacated by Supreme Court)
- Litton Fin. Printing Div. v. N.L.R.B., 501 U.S. 190 (1991) (collective‑bargaining agreements may in explicit terms continue benefits after expiration; language may be express or implied)