A district court in West Virginia recently held that retirees were not entitled to lifetime health benefits under the clear and unambiguous language of the relevant collective bargaining agreements.  Shortly after Constellium modified retiree health benefits to provide less favorable coverage, the retirees sued, alleging that they had a vested right to the prior level of health benefits.  The court held that the retirees were not entitled to lifetime benefits in light of clear and unambiguous durational clauses in the CBAs that limited retiree health benefits to the term of the labor agreement.  Since the language was clear, the court also found that it should not consider extrinsic evidence.  The case is Barton v. Constellium Rolled Products-Ravenswood, LLC, 13-cv-03127, 2016 WL 51262 (S.D. W. Va. Jan. 4. 2016).