"First, the Court restated some of the more employer-friendly language from its previous case.... Next, the Court set out a series of principles of contract interpretation that should be applied to plan interpretation, all of which generally tend to weigh against a finding of lifetime 'vesting' of retiree health benefits... Employers also will be heartened by the Court's rejection of the Sixth Circuit's holding that retiree health benefits are a form of deferred compensation." [M&G Polymers USA, LLC v. Tackett, No. 13-1010 (U.S. Jan. 26, 2015)]