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Home / Opinion / 09-2964 Central States, Southeast & Southwest Areas Pension Fund v. Auffenberg Ford, Inc.

09-2964 Central States, Southeast & Southwest Areas Pension Fund v. Auffenberg Ford, Inc.

Labor ERISA; modification An oral agreement cannot modify a written agreement, even if written notice is provided. “Auffenberg cites Central States, Southeast & Southwest Areas Pension Fund v. Behnke, Inc., 883 F.2d 454 (6th Cir. 1989), in support of the proposition that CBAs can be orally modified as long as written notice is given. But the Behnke case ...

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