"[T]he employer/petitioner asserts that the earlier decision by the Sixth Circuit Court of Appeals conflicts with every other circuit in the country, in holding that an absence of language in a Collective Bargaining Agreement (CBA) about how long retirees will be entitled to their health care benefits creates an 'inference' that they are vested for life.... The employer claims that on the opposite end of the spectrum is the Third Circuit Court of Appeals which holds that retiree health care benefits will only be considered vested indefinitely when the CBA includes a clear statement of such intention. In the middle of the spectrum are multiple circuit courts, including the Second and Seventh, that hold that at least some language in a CBA must support the interpretation that health benefits will be vested indefinitely." [M&G Polymers USA, LLC v. Tackett, No. 13-1010 (on appeal from 6th Cir., cert. granted May 5, 2014)]