"The imperative to establish a uniform labor policy requires a consistent and easy to understand test for determining when, in the case of a health plan created in collective bargaining, retirees become vested in a right to receive health-care benefits that cannot be either terminated or altered after the contract itself has expired. The only test consonant with ERISA, federal common law under the NLRA, and general principles of contract law, is one which requires clear and unmistakable language evincing the plan sponsor's intention to vest retired participants in a right to receive such significant and costly employer- provided benefits in perpetuity." [M&G Polymers USA, LLC v. Tackett, No. 13-1010 (on appeal from 6th Cir., cert. granted May 5, 2014)]

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