Over the past decade, there has been an explosion of litigation addres
sing an employer's right to unilaterally amend or terminate medical be
nefits provided to retirees. The sheer volume of these cases and the v
ariety of facts and legal theories have combined to obscure the patter
ns and trends that actually are emerging from this litigation. This ar
ticle will describe the context of the struggle over retiree benefits
and discuss those leading decisions in which the federal courts of app
eals have established their rules for deciding retiree benefits cases.