Arbuckle v. General Motors, LLC (Opinion on Application)Annotate this Case
Plaintiff Clifton Arbuckle sustained a work-related back injury while working for General Motors Corporation (GM), and in May 1993 began receiving a disability pension. He retired that month and was subsequently awarded workers’ compensation benefits. Later, he also received Social Security Disability Insurance (SSDI) benefits. GM and the International Union, United Automobile, Aerospace and Agricultural Implement Workers of America (UAW) had executed a letter of agreement in 1990 in which GM agreed not to coordinate workers’ compensation and disability pension benefits for its employees under MCL 418.354. This letter of agreement was incorporated into the 1990 collective-bargaining agreement (CBA) between GM and the UAW and was intended to remain in place until termination or amendment of the CBA, which expired in November 1993. When the CBA expired, however, the provision against coordination was continued in subsequent letters of agreement and incorporated into subsequent CBAs. In 2009, GM and the UAW adopted a formula (incorporated into the 2009 CBA) by which GM would coordinate benefits, using disability pension benefits to reduce the amount of workers’ compensation benefits for all workers and retirees, regardless of when they had retired. GM advised Arbuckle that effective January 1, 2010, his benefits would be reduced using the formula in the 2009 agreement. Arbuckle appealed to the Workers’ Compensation Agency, which ultimately concluded that GM was improperly using Arbuckle’s SSDI benefits to offset his workers’ compensation benefits, in violation of MCL 418.354(11). A workers’ compensation magistrate reversed the director’s ruling but nevertheless concluded that GM was prohibited from reducing Arbuckle’s workers’ compensation benefits by his disability pension benefits because Arbuckle had never agreed to coordination of benefits and no evidence established that the UAW had the authority to bargain on Arbuckle’s behalf after his retirement. The Michigan Compensation Appellate Commission (MCAC) reversed in part, holding that irrespective of the UAW’s authority to bind retirees, GM was permitted to coordinate Arbuckle’s disability pension benefits. Arbuckle sought leave to appeal, but after the Court of Appeals granted his application, he died. Robert Arbuckle, the personal representative of the estate, was substituted as plaintiff. The Court of Appeals reversed in an unpublished opinion per curiam and remanded the case for further proceedings. GM then appealed. The Supreme Court concluded after its review that the Court of Appeals erred in holding that GM lacked the authority to coordinate Arbuckle’s benefits under the 2009 CBA. The Court reversed and reinstated MCAC's order.