## Facts

- An employer acquired a West Virginia plant and entered into a master collective-bargaining agreement (CBA) and a related Pension, Insurance, and Service Award agreement with the union.
- The retiree medical provisions stated that eligible retirees (and certain spouses/dependents) would receive a full company contribution toward health-care benefits, and that benefits would be provided for the duration of the agreement.
- The agreements contained a general term/duration and were subject to renegotiation after a set period.
- After the agreements expired, the employer required retirees to contribute to health-care costs.
- Retirees sued under LMRA § 301 and ERISA, alleging vested, lifetime, contribution-free retiree health benefits.
- The district court dismissed, the court of appeals reversed under a circuit doctrine inferring vesting of retiree medical benefits absent clear contrary language, and after trial the district court entered judgment for retirees; the court of appeals affirmed using the same approach.

## Issues

1. Whether retiree health benefits in a CBA may be treated as presumptively vested for life based on inferences favoring vesting when the agreement is silent or ambiguous on duration.
2. Whether CBAs establishing retiree health benefits must instead be interpreted under ordinary principles of contract law, including application of general durational clauses absent contrary language.

## Decision

- The Supreme Court unanimously vacated the court of appeals’ judgment and remanded.
- The Court held that CBAs, including those establishing ERISA plans, must be interpreted according to ordinary principles of contract law.
- The Court rejected the lower court’s interpretive approach that placed a thumb on the scale toward lifetime vesting of retiree medical benefits.
- The Court did not decide whether the particular retirees’ benefits vested; it required the lower court to interpret the agreements anew without the rejected presumptions.

## Legal Principles

- Collective-bargaining agreements are construed using ordinary contract principles so long as they do not conflict with federal labor policy.
- A court may not infer lifetime vesting of retiree medical benefits from silence or ambiguity regarding duration.
- General durational clauses ordinarily apply to all contractual promises, including retiree medical benefits, unless specific language indicates a different duration.
- Ambiguous writings should not be construed to create lifetime obligations; lifetime commitments require clear, affirmative evidence of intent.
- Interpretive doctrines that systematically favor one side over the other distort the task of determining the parties’ intent from the agreement’s text.

## Conclusion

The Court required lower courts to interpret retiree health-benefit provisions in CBAs under standard contract rules, rejecting special pro-vesting inferences and remanding for reconsideration without any presumption that retiree medical benefits continue for life beyond the agreement’s term.


M&G Polymers USA, LLC v. Tackett, 574 U.S. 427 (2015)