In City of Pittsburgh v. Fraternal Order of Police, Fort Pitt Lodge No. 1, 911 A.2d 651 (Pa. Cmwlth. 2006), an Act 111 arbitration panel issued an award that capped the City's obligation to pay for post-retirement insurance at the cost prevailing on the date of the employee's retirement. On appeal, the union argued that any diminution of post-retirement insurance benefits below the level expected by employees violated the Contracts Clauses of the United States and Pennsylvania Constitutions. The Court held that the constitutions did not preclude changes in benefits, even when enjoyed post-retirement, if the changes were the result of arms-length union contracts or Act 111 contract awards. Rather, constitutional concerns are raised when there are "unilateral changes in contractual benefits, not changes that are entered by mutual agreement in a contract or by an Act 111 panel." Id. at 653.