Tackett v. M & G POLYMERS, USA, LLC
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
They apply the pleading standards in Tackett v. M & G Polymers, USA, LLC; their nearby adverse language concerns other authorities, principally Jones v. Bock overruling McGore v. Wrigglesworth. The separately retrieved Supreme Court decision in M&G Polymers USA, LLC v. Tackett supplies the confirmed treatment listed below: it expressly rejects the 2009 decision’s vesting analysis under International Union, United Automobile, Aerospace & Agricultural Implement Workers of America v. Yard-Man, Inc. and vacates the subsequent 2013 judgment. This treatment does not displace the 2009 decision’s pleading or subject-matter-jurisdiction rules.
1,497 later cases cite Tackett v. M & G POLYMERS, USA, LLC; 393 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.
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Treatments
Abrogated
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The 2009 Tackett decision’s reliance on Yard-Man inferences to infer an intent to vest retiree health-care benefits is inconsistent with ordinary contract law.
M&G Polymers USA, LLC v. Tackett · Supreme Court of the United States · filed
There is no doubt that Yard-Man and its progeny affected the outcome here. As in its previous decisions, the Court of Appeals here cited the “context of . . . labor-management negotiations” and reasoned that the Union likely would not have agreed to language ensuring its members a “full Company contribution” if the company could change the level of that contribution. Tackett I, 561 F. 3d, at 490 (internal quotation marks omitted). It similarly concluded that the tying of eligibility for health care benefits to receipt of pension benefits suggested an intent to vest health care benefits. Ibid. And it framed its analysis from beginning to end in light of the principles it announced in Yard-Man and its progeny. See 561 F. 3d, at 489; see also Tackett II, 733 F. 3d, at 599–600. We reject the Yard-Man inferences as inconsistent with ordinary principles of contract law.
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