Whether a notice of termination for a collective bargaining agreement must contain a clear statement of an intent to terminate the agreement

QUESTION PRESENTED Collective bargaining agreements often have provisions known as “evergreen” clauses, which automatically extend the agreement for a fixed period if no party gives timely written notice that it wants the agreement to end. The question presented is: Whether a notice of termination for a collective bargaining agreement must contain a clear statement of an intent to terminate the agreement, as the Sixth and Seventh Circuits hold, or must contain specific wording only when the agreement requires it, as the First and Third Circuits and National Labor Relations Board hold.