"Justice Thomas' opinion makes clear that any inferences of the type adopted by the Sixth Circuit must be based on facts found in the record, not on the courts 'suppositions about the intentions of employees, unions, and employers negotiating retiree benefits.' ... Importantly, the analytic framework adopted by the Supreme Court requires that future courts confronting vesting questions conduct a traditional analysis of the contractual language, only relying on extrinsic evidence if a material term is ambiguous." [M&G Polymers USA, LLC v. Tackett, No. 13-1010 (U.S. Jan. 26, 2015)]  MORE >>