A federal district court in Ohio dismissed retirees’ claims for lifetime healthcare benefits from Honeywell. Honeywell provided healthcare benefits to plaintiffs through a series of collective bargaining agreements and, although it continued to do so for several years after the final CBA expired, Honeywell eventually notified plaintiffs that it would terminate contributions toward their healthcare benefits. 

Applying the principles set forth in M&G Polymers USA, LLC v. Tackett, 135 S. Ct. 926 (2015) and the Sixth Circuit’s subsequent decision in Gallo v. Moen, Inc., 813 F.3d 265 (6th Cir. 2016), the district court held that plaintiffs’ healthcare benefits did not vest because the CBAs were for three-year terms and did not expressly state that the healthcare benefits vested, whereas the CBAs did expressly vest pension benefits for life.  Although, unlike in Gallo, there was no reservation-of-rights clause, the court held that such a clause was not required to find that the CBAs unambiguously did not provide lifetime health benefits to plaintiffs.

The case is Watkins v. Honeywell Int’l, Inc., No. 16-1925, 2016 WL 7325161 (N.D. Ohio Dec. 16, 2016).