"[In] the last significant Sixth Circuit decision on this topic, Reese v. CNH America LLC, the Court ... concluded that the employer could unilaterally modify a retiree health plan, provided that the modifications were reasonable. That decision seemed to put the Sixth Circuit more in line with other circuits that had ruled on these issues, and gave employers some relief. But it appears that relief was short-lived.... But does this [new] decision mean that if the company maintains a defined contribution private exchange, it must maintain a standalone insured plan for this group of retirees?... This brings us back to the question: do retirees really want 2006 health care?" [United Steel Workers v. Kelsey-Hayes Company, No. 13-1717 (6th Cir. Apr. 22, 2014)]