Noe v. PolyOne Corp.’s Empirical Analysis
520 F.3d 548 · 2008
Citation profile
22 federal appellate ·
How this case has been cited
Cited by 47 later decisions (3 by the Supreme Court) — most recently November 2020 · most notably Tackett v. M & G Polymers, USA, LLC (2009), 135 S. Ct. 926 - M&G Polymers United States, LLC v. Tackett (2015)
22 federal appellate ·
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Sprague v. General Motors Corp. · International Union United Automobile Aerospace and Agricultural Implement Workers of America Uaw v. Yard-Man Incorporated · McGee v. Marcum · Golden v. Kelsey-Hayes Co. · Bidlack v. Wheelabrator Corp.
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 47 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[C]ourts must first examine the CBA language for clear manifestations of an intent to vest. [Yard-Man, 716 F.2d at 1479 ]. Furthermore, each provision of the CBA is to be construed consistently with the entire CBA and “the relative positions and purposes of the parties.” Id. The terms of the CBA should be interpreted so as to avoid illusory promises and superfluous provisions. Id. at 1480 . Our decision in Yard-Man also explained that “retiree benefits are in a sense ‘status’ benefits which, as such, carry with them an inference ... that the parties likely intended those benefits to continue as long as the beneficiary remains a retiree.” Id. at 1482 . With regard to the “Yard-Man inference,” later decisions of this court have clarified that Yard-Man does not create a legal presumption that retiree benefits are interminable. Yolton, 435 F.3d at 579 . Rather, Yard-Man is properly understood as creating an inference only if the context and other available evidence indicate an intent to vest. Id.”
3 later decisions quote this exact passage · from the majority“ties eligibility for retirement-health benefits to eligibility for a pension ... [leaves] little room for debate that retirees' health benefits ves[t] upon retirement.”
3 later decisions quote this exact passage · from the majority“'[a]bsent specific durational language referring to retiree benefits themselves,' a general durational clause says nothing about the vesting of retiree benefits.”
3 later decisions quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.