Lynnette Kaiser v Alcoa USA Corp., 25-1627

In this ERISA and LMRA § 301 dispute, retirees challenged Alcoa's termination of healthcare benefits for pre-1993 retirees, arguing that silent collective bargaining agreements (CBAs) implicitly vested lifetime benefits. The district court certified a class under Rule 23(b)(2), granted partial summary judgment on liability based on judicial estoppel—relying on Alcoa's statements in a separate Sixth Circuit case (Curtis v. Alcoa)—and ordered reinstatement of benefits plus a reimbursement claims process. Alcoa appealed both the certification and summary judgment rulings.

The Seventh Circuit affirmed class certification, holding that commonality and typicality were satisfied because all relevant CBAs were uniformly silent on the duration of retiree benefits, and Plaintiffs presented common objective evidence—including testimony from Alcoa's lead negotiator—suggesting a latent ambiguity as to whether the parties intended these benefits to vest. The court also upheld Rule 23(b)(2) certification, finding the primary relief sought was injunctive, with the reimbursement process constituting only incidental monetary relief calculable through a mechanical formula, consistent with Johnson v. Meriter.

However, the court reversed the grant of summary judgment on judicial estoppel grounds. Applying the New Hampshire v. Maine framework, the court found that Alcoa's statements in the Curtis litigation—which concerned post-1993 retirees and a benefits cap—were not clearly inconsistent with its position regarding pre-1993 retirees in this case. Because the prior statements did not squarely address vesting for the pre-1993 class, judicial estoppel could not bar Alcoa from contesting liability on the merits. This decision underscores the fact-specific rigor courts apply when assessing 'clear inconsistency' across separate proceedings and reaffirms flexible standards for class certification in ERISA benefits litigation.