Intl U Utd Auto v. Arvinmeritor Inc, 2:03-cv-73872

Background

Plaintiffs (retirees) sued Meritor, Inc. over promised retiree healthcare benefits, including monthly Medicare Part B premium reimbursements for retirees and surviving spouses who receive a pension.
The court previously granted defendants' motion to dissolve an injunction and entered judgment for defendants on September 6, 2017; plaintiffs moved for reconsideration on September 20, 2017.
Plaintiffs argued the court misapplied forfeiture rules and failed to consider durational language in the CBAs that they say vest the Part B reimbursement obligation.
The CBAs incorporate Exhibit B and Exhibit B-1; Exhibit B contains a durational clause tying the insurance program to termination of the National Agreement, and Exhibit B states it supersedes Exhibit B-1 on conflict.
The court found plaintiffs forfeited meaningful briefing of the Part B issue before the Sixth Circuit and this court, and ruled that Exhibit B’s durational clause unambiguously limits Part B reimbursements to the life of the National Agreement.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether plaintiffs preserved the Medicare Part B reimbursement argument	Plaintiffs: They raised Part B at an August 30 hearing and the promise has been part of prior proceedings; thus not forfeited	Meritor: Plaintiffs did not timely brief or seek leave to brief the issue before the Sixth Circuit or this Court, so it is forfeited	Court: Forfeited — plaintiffs failed to timely raise and brief the issue, so court need not consider it
Whether Medicare Part B reimbursements are vested/durationally separate from CBA expiration	Plaintiffs: The Part B promise is separately worded and tied to receiving a pension; this shows vesting or at least ambiguity requiring trial	Meritor: Exhibit B ties all Exhibit B-1 healthcare promises (including Part B) to termination of the National Agreement, so no vesting beyond CBA expiration	Court: Unambiguous — Exhibit B’s durational clause limits Part B reimbursements to the termination of the National Agreement; no vesting
Whether Cole IV limited appellate review to only certain language, leaving Part B open	Plaintiffs: Sixth Circuit didn’t review the specific Part B provisions, so this court can revisit scope and extrinsic evidence	Meritor: Sixth Circuit’s ruling reversing the court’s prior reliance on Yard-Man applies across the board to healthcare promises in Exhibit B/B-1	Court: Cole IV’s analysis applies; court cannot revive earlier findings that relied on the now-abrogated inference
Whether plaintiffs are entitled to Rule 56 or trial on Part B issue	Plaintiffs: Deny summary resolution; claim factual/contractual ambiguity requires trial	Meritor: Contract language is clear; no factfinding required	Court: No trial or Rule 56 warranted because the contract unambiguously ties benefits to CBA duration and plaintiffs forfeited argument

Key Cases Cited

Lamson & Sessions Co. v. Peters, [citation="576 F. App'x 538"] (6th Cir.) (forfeiture and appellate briefing principles)
Howe v. City of Akron, 801 F.3d 718 (6th Cir. 2015) (forfeiture/waiver principles in appellate review)
Cole v. Meritor, Inc., 855 F.3d 695 (6th Cir. 2017) (interpreting CBA durational clauses limiting healthcare promises to the life of the CBA)
Reese v. CNH Indus. N.V., 854 F.3d 877 (6th Cir. 2017) (discussing when segregated healthcare promises create ambiguity)
Gallo v. Moen Inc., 813 F.3d 265 (6th Cir. 2016) (contractual obligations cease upon termination of the bargaining agreement)
M & G Polymers USA, LLC v. Tackett, 135 S. Ct. 926 (2015) (principle that contractual obligations generally end with the bargaining agreement)