American Commercial Lines obtains summary judgment in multi-million dollar retiree medical benefits case
Clients American Commercial Lines LLC and ACL Transportation Services, LLC
On November 30, 2010, Jones Day attorneys achieved a significant summary judgment victory for its clients American Commercial Lines LLC and ACL Transportation Services, LLC (the "ACL Defendants") in a lawsuit brought by the United Mine Workers of America ("UMWA") and several retirees (represented by the UMWA). The lawsuit alleged that the ACL Defendants violated the Labor Management Relations Act (LMRA) and the Employee Retirement Income Security Act ("ERISA") in 2008 by modifying the healthcare benefits the companies provided to the retirees. Specifically, after the retirees' medical, pharmacy, and vision benefits were modified pursuant to a new collective bargaining agreement between the UMWA and ACLTS in 2008, Plaintiffs filed suit alleging that the modifications violated the provisions of previous collective bargaining agreements between the parties, which, they alleged, guaranteed them lifetime healthcare benefits that were vested and could never be modified during their lifetime.
Following a lengthy period of discovery that involved a significant number of depositions and a voluminous production of paper documents, the ACL Defendants moved for summary judgment on all of Plaintiffs' claims. While the ACL Defendants' summary judgment motion was pending, Jones Day attorneys successfully moved on behalf of its clients to strike a substantial portion of the evidence submitted by the Plaintiffs in opposition to the ACL Defendants' motion for summary judgment. Additionally, Jones Day attorneys convinced the United States Court of Appeals for the Eighth Circuit to deny the Plaintiffs' petition for interlocutory appeal even after the district court had certified the case for interlocutory appeal, which avoided an appeal that could have significantly delayed a resolution of the case on the merits.
In granting summary judgment to the ACL Defendants, the court held that Plaintiffs failed to satisfy their burden to prove that the retirees' health care benefits were vested under collective bargaining agreements or medical plans in existence prior to 2008. Indeed, the Court noted that "the relevant CBAs and the applicable plan documents . . . explicitly and unambiguously reserve to defendants the right to terminate, modify, or amend the retiree medical benefits provided to the Retiree Plaintiffs . . . No relevant CBA or applicable plan document contains an express promise to vest the subject retiree medical benefits . . ." Moreover, the Court explicitly rejected Plaintiffs' argument that the UMWA never agreed to negotiate retiree medical benefits for the retiree Plaintiffs because it was a permissive subject of collective bargaining. Ultimately, in granting summary judgment, the court held that the ACL Defendants were not obligated to provide medical benefits to the retirees pursuant to the terms of any contract or medical plan other than those provided by the 2008 contract and its applicable medical plan.
United Mine Workers of Am., et al. v. Am. Comm. Lines LLC, et al., No. 4:08-cv-1777 (E.D. Mo. Nov. 30, 2010)