ERISA-Sixth Circuit Refuses To Uphold The Grant Of A Preliminary Injunction Barring The Employer From Terminating Retiree Healthcare  

In Cooper v. Honeywell International, Inc., No., 17-1042 (6th Cir. 2018), the issue was whether retiree healthcare benefits in a collective bargaining agreement (“CBA”) should extend beyond the CBA’s expiration.  Rebecca Cooper and some 50 other retirees at Honeywell International’s Boyne City, Michigan plant allege that Honeywell must provide them healthcare benefits until they reach age 65.  Honeywell responds that its obligation to provide those benefits ended when its CBA with the Boyne City employees expired in March 2016.

While waiting for the district court to rule on the matter, the retirees sought a preliminary injunction barring Honeywell from terminating their healthcare.  The district court granted the injunction, concluding that the retirees had shown both a likelihood of success on the merits and that they would suffer irreparable harm without such relief.

Upon reviewing the case, the Sixth Circuit Court of Appeals (the “Court”) said that, because it finds that the retiree healthcare benefit provision in the CBA did not clearly provide an alternative end date to the CBA’s general durational clause, it concludes that Cooper has not shown a likelihood of success on the merits.  Thus, the Court reversed the decision of the district court, thereby not allowing the retirees to obtain the preliminary injunction.


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