In the case of United Mine Workers of America Health & Retirement Funds et al. v. Robinson et al., 1981, the Supreme Court ruled in favor of the United Mine Workers (UMW) union's health and retirement funds. The case was brought by retired coal miners who were denied benefits after their employer ceased operations without a successor company to assume its obligations under an industry-wide collective bargaining agreement with UMW. They sued for entitlement to lifetime health benefits from UMW's benefit trusts, arguing that they had vested rights based on language in previous agreements and trust documents. The court held that neither federal labor law nor trust law required these trusts to provide unalterable vesting of welfare benefits or prevented them from changing eligibility requirements for such non-pension benefits as medical coverage. It also found no contractual obligation on part of the trustees or employers contributing to multiemployer plans like those at issue here, which are common in industries characterized by small companies with high employee turnover rates and uncertain futures.

In the dissenting opinion for United Mine Workers of America Health & Retirement Funds v. Robinson, Justice William Rehnquist argued that the majority's decision to allow miners who had not signed a National Bituminous Coal Wage Agreement (NBCWA) to receive health and retirement benefits was incorrect. He contended that this ruling contradicted previous court decisions which held that trust funds like those established by NBCWAs are only obligated to provide benefits as explicitly outlined in their agreements. In his view, extending these benefits beyond what is specified in the agreement would undermine its purpose and potentially jeopardize its financial stability. Furthermore, he disagreed with the majority’s interpretation of congressional intent behind relevant labor laws, arguing they were designed to encourage collective bargaining rather than mandate specific outcomes from such negotiations.