Kelly v. Honeywell International, Inc., No. 17-675 (2d Cir. 2019)
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Where a collective bargaining agreement contains unambiguous language vesting welfare benefits, the agreement's general durational clause does not prevent those benefits from vesting. The Second Circuit held that the effects bargaining agreement (EBA) unambiguously vested medical coverage for retirees who retired prior to the expiration of the EBA. Therefore, the court affirmed the district court's judgment in favor of union retirees who retired prior to the expiration of the EBA and their surviving spouses, and its order permanently enjoining Honeywell from terminating medical coverage for those union retirees and their surviving spouses.
The court held that the EBA was ambiguous as to whether medical coverage for union retirees who retired after the EBA expired and their surviving spouses vested. Nonetheless, the court held that the Post‐Expiration Plaintiffs have presented a sufficiently serious question as to the merits and satisfied the remaining requirements for a preliminary injunction to issue. Accordingly, the court affirmed the district court's order preliminarily enjoining Honeywell from terminating the Post‐Expiration Plaintiffs' medical benefits and remanded for further proceedings
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