Maytag Corp. v. International Union, United Automobile, Aerospace & Agricultural Implement Workers, 687 F.3d 1076

Maytag’s SIAs provided retiree health benefits, each an ERISA employee welfare benefit plan.
Whirlpool acquired Maytag in 2006 and assumed its CBA obligations, including retiree benefits.
In 2008 Whirlpool proposed synchronizing retiree benefits with its salaried plans; the Union refused to bargain retiree health benefits.
Whirlpool filed a declaratory judgment action on July 24, 2008 seeking to test unilateral modification of retiree benefits.
Newton retirees were notified of changes effective January 1, 2009; a mirror-image class action followed in Michigan.
The district court held that a live Article III controversy existed and certified a retirees’ class; the Union appeals.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether an Article III case or controversy existed at filing.	Whirlpool argued a real dispute existed due to vested rights test.	Union argued no controversy until retirees’ positions formed later.	Yes; substantial, immediate controversy existed at filing.
Whether retirees have vested rights to 2004 SIA benefits under ERISA.	Union failed to prove vesting; benefits were not unambiguous vesting language.	Union asserted extrinsic evidence showed vesting intent in past bargaining.	No vesting; SPD and plan documents unambiguously reserved right to modify.
Role of extrinsic evidence and SPD in vesting determination.	Extrinsic evidence should support vesting given bargaining history.	SPD devoid of vesting language and reserved rights defeats vesting.	Extrinsic evidence not required where SPD clearly reserves rights; vesting not shown.

MedImmune, Inc. v. Genentech, Inc., 549 U.S. 118 (U.S. 2007) (actual controversy and declaratory relief standards clarified)
Maryland Casualty Co. v. Pacific Coal & Oil Co., 312 U.S. 270 (U.S. 1941) (test for existence of declaratory relief controversy)
Aetna Life Ins. Co. v. Haworth, 300 U.S. 227 (U.S. 1937) (declaratory relief and controversy requirements)
Hyatt Int’l Corp. v. Coco, 302 F.3d 707 (7th Cir. 2002) (contractual disputes and necessity for declaratory relief)
Steger v. Franco, Inc., 228 F.3d 889 (8th Cir. 2000) (standing and timing in declaratory actions)
John Morrell & Co. v. Commercial Workers Int’l Union, 37 F.3d 1302 (8th Cir. 1994) (vesting burden with respect to ERISA benefits without clear vesting language)
Crown Cork & Seal Co. v. Int’l Ass’n of Machinists, 501 F.3d 912 (8th Cir. 2007) (reservation of rights defeats vesting)
Jensen v. SIPCO, Inc., 38 F.3d 945 (8th Cir. 1994) (extrinsic evidence and vesting analysis in ERISA plans)
Hughes v. 3M Retiree Med. Plan, 281 F.3d 786 (8th Cir. 2002) (SPD language and vesting conclusions)
Alpha Portland Indus., Inc., 836 F.2d 1519 (8th Cir. 1988) (durational clauses and vesting implications)
DeGeare v. Alpha Portland Indus., Inc., 837 F.2d 812 (8th Cir. 1988) (ERISA plan language and vesting analysis)