"In concluding that the parties intended to confer lifetime benefits to the retirees ... the Court relied heavily on contract language tying eligibility for contribution-free healthcare benefits to eligibility for pension benefits.... However ... [M&G Polymers v. Tackett] forecloses reliance on this rationale ... Tackett suggests that courts should not rely on language 'tying.... eligibility for health care benefits to receipt of pension benefits.' ... It does not suggest that courts cannot rely on language tying the duration of retiree healthcare benefits to the receipt of benefits. There is a difference.... [T]he tying language used here no longer supports the Court's determination that the parties intended to confer lifetime benefits." [Reese v. CNH Industrial N.V., No. 04-CV-7059 2 (E.D. Mich. Sept. 28, 2015)]

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