Maytag Corp. v. Int'l Union, No. 11-2931 (8th Cir. 2012)
Annotate this CaseThe United Automobile, Aerospace, and Agricultural Implement Workers International Union and Local 997 appealed the district court judgment after a five-day bench trial declaring that Whirlpool Corporation may unilaterally modify the health care benefits it provided to retired hourly workers previously employed at the Newton, Iowa manufacturing facilities of Whirlpool's now-dissolved subsidiary, Maytag Corporation. The Eighth Circuit Court of Appeals affirmed, holding (1) the district court correctly found that a case or controversy existed when Whirlpool filed its declaratory judgment action; and (2) the retirees did not have a vested right to the previously granted health benefits under ERISA, as the benefits were provided in a collectively bargained agreement that had no express vesting provision.
Court Description: Civil case - ERISA. An actual Article III case or controversy existed at the time Whirlpool filed its action in July, 2008 as Whirlpool reasonably believed, given the history of the matter and its obligations as an ERISA fiduciary, that the contractual dispute with the union was real, substantial, existing and ripe for immediate judicial resolution; district court did not err in finding the retirees did not have a vested right to health benefits as the ERISA plan documents contained no vesting language and stated that the benefits were subject to change and could be terminated.
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