Dewhurst v. Century Aluminum Company, No. 10-CV-1759, 2011 BL 215902 (4th Cir. Aug. 22, 2011) In a certified class action, the U.S. Court of Appeals for the Fourth Circuit held that retirees of a Century Aluminum Company plant (Plant) and their union (collectively, plaintiffs) were not entitled to a preliminary injunction because they did not clearly show that they were likely to succeed on the merits of their case seeking continuation of their healthcare benefits. Relying on District 29, United Mine Workers of America v. Royal Coal Co., 768 F.2d 588 (4th Cir. 1985) (Royal Coal), the Court held that plaintiffs were not entitled to vested retiree healthcare benefits because the applicable collective bargaining agreements (CBAs) and summary plan descriptions (SPDs) provided that retiree healthcare benefits were effective only for the duration of the applicable CBA. The Court rejected plaintiffs' interpretation of the Sixth Circuit's holding in International Union, United Automobile, Aerospace & Agricultural Implement Workers of America v. Yard-Man, Inc., 716 F.2d 1476 (6th Cir. 1983) (Yard-Man), as well as plaintiffs' argument that the Court had adopted such holding in Keffer v. H.K. Porter Co., 872 F.2d 60 (4th Cir. 1989).
Century Announced Plans to Modify or Terminate Retiree Healthcare Benefits
District Court Denied Preliminary Injunction
Preliminary Injunction Standard
Keffer and Yard-Man
CBAs and SPDs Provide for Retiree Healthcare Benefits Only for the Duration of the Applicable CBA
Notes on Another Recent Case
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