Sixth Circuit: Under Contract Law, Whirlpool Not Obligated to Provide Lifetime Retiree Healthcare Benefits
The Sixth Circuit recently followed a line of precedent (and other more recent decisions from the Sixth Circuit) and reversed a 2017 Northern District of Ohio decision finding certain collective bargaining agreements vested plaintiffs with lifetime healthcare benefits, reports Seyfarth Shaw in its ERISA & Employee Benefits Litigation Blog.
The court found that the CBAs covering the retirees lacked clear, affirmative language that Whirlpool had an obligation to fund their health benefits after the expiration of the agreements’ general durational clause.
The court ruled that “either a CBA says clearly and affirmatively — that is unambiguously — that its general durational clause doesn’t control the termination of healthcare benefits, or the clause controls.”