The Sixth Circuit yesterday provided additional guidance in this Circuit for interpreting collective bargaining agreements and preemption questions under the Labor Management Relations Act (LMRA).  The three-judge panel in CNH America LLC v. International Union, et al. (6th Cir., Case No. 09-2001) (PDF), held that a Voluntary Employees’ Beneficiary Association (VEBA) trust fund agreement, which was part … Continue Reading