## Facts

- The City of Waterbury and the firefighters’ union entered successive collective bargaining agreements (CBAs) from 1986 through 1999 that expressly provided medical benefits for retirees, their spouses, and eligible dependents.
- CBA language stated the city “shall continue in full force and effect the benefits” for retirees and certain surviving family members.
- After 1999, the city sought to reduce retiree medical benefits due to rising health-care costs and severe fiscal distress; negotiations failed and the dispute proceeded to arbitration.
- A state-created fiscal oversight entity, formed by Special Act 01-1 with broad authority over the city’s finances and labor contracts, approved reductions to retiree medical benefits.
- Retired firefighters and surviving spouses sued, alleging a vested contractual right to the specific medical benefits in effect when each firefighter retired and seeking restoration of those benefits.
- The trial court construed the CBAs to create vested lifetime rights to the specific benefit level at retirement, concluded the oversight entity lacked authority to alter those benefits, and entered a permanent injunction ordering reinstatement.

## Issues

1. Whether the retirees had a vested contractual right to the specific level of retiree medical benefits in place at the time of retirement, rather than to retiree medical benefits in general.
2. Whether the oversight entity’s statutory authority under Special Act 01-1 permitted approval of modifications to retiree medical benefits consistent with the retirees’ contractual rights.
3. Whether a permanent injunction reinstating the prior benefit package was proper.

## Decision

- The Connecticut Supreme Court reversed.
- The court held the retirees had a vested right to retiree medical benefits generally, but not a vested right to the specific benefit package or level contained in the CBA in effect at retirement.
- Because the trial court’s permanent injunction rested on the erroneous conclusion that the specific benefits were vested and immutable, the injunction could not stand.
- The case was remanded for further proceedings consistent with the limited vesting recognized by the court.

## Legal Principles

- Retiree medical benefits may vest as a contractual entitlement to coverage based on CBA language and the parties’ course of dealing.
- A vested right to retiree medical benefits does not, without clear and unmistakable contractual language, include a lifetime guarantee of the specific benefit design or level in effect at retirement.
- Courts are reluctant to construe time-limited CBAs to impose perpetual, unchangeable obligations absent unequivocal language.
- Equitable relief restoring a particular benefit level is improper when the underlying contractual right is limited to continued coverage rather than a fixed package of specific terms.
- Statutory fiscal oversight authority may operate to permit modification of non-vested elements of retiree benefits without unlawfully impairing vested contractual rights.

## Conclusion

The court concluded that retired firefighters were contractually entitled to continued retiree medical coverage, but not to a permanent lock-in of the specific benefit level at retirement; it therefore reversed the injunction requiring reinstatement of prior benefits and allowed benefit modifications consistent with that limited vested right.


Poole v. City of Waterbury, 831 A.2d 211 (Conn. 2003)