In Cooper v. Honeywell International, Inc., No. 17-1042 (6th Cir. 2018), the Sixth Circuit Court of Appeals (the “Court”) was faced with another case dealing with whether retiree benefits in a collective bargaining agreement (the “CBA”) should extend beyond the CBA’s expiration. Rebecca Cooper and some 50 other retirees at Honeywell International’s Boyne City, Michigan plant say that Honeywell must provide them healthcare benefits until they reach age 65. Honeywell responds that its obligation to pay those benefits ended when its CBA with the Boyne City employees expired in March 2016.
In this case, while waiting for the district court to decide the case, 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 Court said that because we find that the retiree healthcare benefit provision in the CBA did not clearly provide an alternative end date to the CBA’s general durational clause, or otherwise show an intent to vest the retiree healthcare benefits beyond the CBA’s expiration date, the Court concludes that Cooper has not shown a likelihood of success on the merits, and thus the Court reverses the decision of the district court to grant a preliminary injunction.
In so ruling, the Court pointed to two recent Supreme Court cases, CNH Industrial N.V., v. Reese, 583 U.S. ___ (2018) and Kelsey-Hayes Co. v. Int’l Union, 583 U.S. ___ (2018), in which the Supreme Court overturned Sixth Circuit decisions and established the rule that the general durational clause of a CBA should dictate when benefits expire, unless an alternative end date is provided.