No. ____ IN THE Supreme Court of the United States _________ SIGNODE INDUSTRIAL GROUP LLC AND ILLINOIS TOOL WORKS, INC., Petitioners, v. HAROLD STONE ET AL., Respondents. ________ On Petition for a Writ of Certiorari to the United States Court of Appeals for the Seventh Circuit ________ PETITION FOR A WRIT OF CERTIORARI ________ JOSEPH J. TORRES Counsel of Record CLIFFORD W. BERLOW EMMA J. O’CONNOR JENNER & BLOCK LLP 353 N. Clark Street Chicago, IL 60654 (312) 222-9350
[email protected] Counsel for Petitioners i QUESTION PRESENTED Whether the Seventh Circuit erred by holding, in conflict with decisions reached by at least two other federal courts of appeals and in spite of this Court’s holdings in M & G Polymers USA, LLC v. Tackett, 135 S. Ct. 926 (2015) and CNH Industrial N.V. v. Reese, 138 S. Ct. 761 (2018) (per curiam) that collective bargaining agreements must be interpreted according to generally applicable principles of contract law, that a collective bargaining agreement with an “express statement[] extending benefits beyond the term of agreement” irrefutably confers vested, lifetime benefits, even if the agreement separately reserves for the employer the right to terminate the agreement in its entirety. ii PARTIES TO THE PROCEEDINGS BELOW AND RULE 29.6 STATEMENT Petitioner Signode Industrial Group LLC is an indirect wholly owned subsidiary of Crown Holdings Inc.; Petitioner Illinois Tool Works, Inc. has no parent. The petitioners are Signode Industrial Group LLC and Illinois Tool Works, Inc. The respondents are Harold Stone, John Woestman, and United Steel, Paper & Forestry, Rubber, Manufacturing, Energy, Allied Industrial & Service Workers International Union, AFL-CIO-CLC (USW).