"The Supreme Court's opinion rejects the three rationales most commonly employed in support of claims for lifetime retiree health benefits -- that the benefits are deferred compensation, that to prevent vesting the agreement must explicitly curtail the duration of the benefits, and that the duration of the health benefit is tied to the lifetime payment of pension benefits. This does not mean that employers will always prevail, but it should lessen the concerns by employers about litigating retiree benefit claims in the Sixth Circuit, as well as the inconsistency multi-jurisdictional employers faced by having different outcomes in different circuits." [M&G Polymers v. Tackett, No. 13-1010 (U.S. Jan. 26, 2015)]