M&G Polymers USA, LLC v. Tackett (13-1010)

argument 13-1010

M&G Polymers USA, LLC v. Tackett

Supreme Court of the United States 52 min 5 speakers 8 chapters transcribed 6 days ago official recording ↗

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What is the opening argument and central issue in M&G Polymers v. Tackett?

John G. Roberts 0:01

Your argument next in case thirteen ten ten, M and G polymers versus TACAT. Ms. Ho?

Unknown 0:07

Thank you, Mr Chief Justice, and may it please the court. A promise of unalterable Cost free health care benefits should be negotiated at the bargaining table. not imposed at the courthouse. In a series of cases, the Sixth Circuit has required courts to infer from contractual silence. a promise of vested benefits. But the the the we're dealing with a case where There isn't silence. I mean It's a m matter of construing what the words mean, but for example This collective bargaining agreement says that the employees will receive a full company contribution to the cost of health benefits. That's our silence. Your honor, respectfully, it is silent with respect to the duration. of the full company contribution toward benefits.

Unknown 1:07

the word receiving, which I understand Your Honor to be focusing on. indicates that the individual has to be retired. other words and actually receiving a pension and receiving a benefit. It's it's not it's not a durational term.

Elena Kagan 1:22

And so you say But there was a hearing by the district court. You you're recommending we apply ordinary contract principles, no?

Unknown 1:31

Yes. There's there's no disagreement and the courts of appeals don't don't disagree that all the time.

Elena Kagan 1:36

Assume that I find those words ambiguous. You have a hearing. The district court had a hearing. And it didn't I don't think the district court relied on a presumption, it relied on a bevy of evidence. including the fact that your company bought The predecessor Company. Assessing the uh health contributions at full value for retirees. Why why wouldn't ordinary contract principles permit the district court to do exactly what it did here?

Unknown 2:12

Just a soda mayor, I want to r go back to the to the first part of your question, which said, Well wasn't wasn't there a trial here? And our position um is that it never it never should have gotten to that because the district judge initially as a matter of law, looked at the contract language here. declined to apply yardman and said, I don't find a promise of vesting. On appeal. The Sixth Circuit said we disagree under yard man. there is at least an inference of vesting here and instructed the district judge to apply yard man honor man, which the district judge did and on page twenty of petitioner's appendix in the opinion on Renee. The district judge says those directives Meaning the six circuits directions in Yardman.

Unknown 3:03

required this court to reach the conclusion that the part that the plaintiffs here obtained vested benefits.

Anthony M. Kennedy 3:10

Ms. Oh, I'm I'm wondering um if you would agree with this. If we could start all over again. Forget all the history that you just said. If we could start all over again. Um You I think just agreed that we would use ordinary contract principles, is that right? Correct. Okay. So ordinary contract principles, we would first we would look at the agreement, and if the agreement said something clearly either way, whether it was for vesting or against vesting, the agreement would control. Is that correct? That's correct. And if the agreement was ambiguous, We could take extrinsic evidence to clarify the terms of the agreement. Is that correct?

Unknown 3:53

Objective extrinsic evidence, yes, that's correct. Okay. So you you acknowledge that? See I I wouldn't acknowledge that if I were you. Well, Your Honor, I'm I'm You don't believe in the parole evidence rule. Abje uh uh uh objective objective extrinsic evidence, Your Honor, would be uh in other words, ad admissible admissible extr uh on a finding ambiguity. But I but I think it's it's important, Justice Kagan, if I may, to point out that in the Sixth Circuit, um and I think this is one way in which what happened here departs from ordinary contract interpretation. Is it in the Sixth Circuit? the inference supplies of vesting based either on text. Or extrinzi extrinsic evidence.

Anthony M. Kennedy 4:37

Yes, I hear you. I was not getting you to agree with Yardman and I was not getting you to agree to the Sixth Circuit. Yes. Is you look at the text, if the text says it either way, you go with the text.