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Case Law Database

Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision

Trustees of Empire State Carpenters Annuity, Apprenticeship, Labor-Management Cooperation, Pension & Welfare Funds v. Allied Design & Construction, LLC

Petitioners, Trustees of Empire State Carpenters Annuity, Apprenticeship, Labor-Management Cooperation, Pension and Welfare Funds, initiated an action to confirm an arbitration award against Allied Design & Construction, LLC. Allied, bound by a collective bargaining agreement, failed to undergo a payroll audit, leading the Funds to estimate a substantial deficiency in contributions. An arbitrator subsequently awarded the Funds $239,901.47, covering the estimated deficiency, interest, liquidated damages, and various fees. The Funds then sought to have this award confirmed by the District Court and requested additional attorneys' fees and costs incurred during the confirmation process. The District Court granted the petitioners' motions, confirming the arbitration award and ordering Allied to pay an additional $737.50 in attorneys' fees and costs.

Arbitration ConfirmationCollective BargainingDelinquent ContributionsAttorney Fees AwardCourt CostsLabor Management Relations ActFederal Arbitration ActSummary Judgment StandardLodestar CalculationUnion Welfare Funds
References
39
Case No. MISSING
Regular Panel Decision

Roca v. Westbury Transport Inc.

This case involves a dispute between the Teamsters Local 814 Pension, Welfare, and Annuity Trust Funds and Westbury Transport, Inc. concerning Westbury's obligation to contribute for an employee, James Dawson. The core issue centers on interpreting the Collective Bargaining Agreement (CBA) regarding 'seniority' and 'seasonal employees,' which dictates the contribution requirements. Both parties moved for summary judgment, presenting conflicting interpretations of the CBA's provisions. The court denied both motions, ruling that a de novo standard of review applies to employer contribution obligations under a CBA, rather than the arbitrary and capricious standard. The court found that the relevant clauses of the CBA were ambiguous, thereby creating genuine issues of material fact that preclude summary judgment and require a trial.

Collective Bargaining AgreementPension FundWelfare FundAnnuity FundTrust AgreementsSummary Judgment MotionContract InterpretationStandard of ReviewDe Novo ReviewArbitrary and Capricious Standard
References
14
Case No. MISSING
Regular Panel Decision

Union Appointed Trustees of the Tapers Industry Insurance & Annuity Funds v. Employer-Appointed Trustees of the Tapers Industry Insurance & Annuity Funds

A dispute arose between the Employer-Appointed Trustees and Union-Appointed Trustees of the Tapers Industry Insurance and Annuity Funds concerning delinquent employer contributions. An arbitrator issued an award, which the Employer-Appointed Trustees sought to confirm and the Union-Appointed Trustees cross-moved to vacate. Judge Walker of the District Court reviewed the arbitration award, noting the arbitrator based his findings on prior judicial decisions rather than independently interpreting the collective bargaining agreement. The Court determined that the arbitrator failed to apply the contract as bargained for by the parties, thus exceeding his authority. Consequently, the Court vacated the arbitration award and remanded the dispute for proceedings consistent with its order.

Arbitration AwardVacate Arbitration AwardConfirm Arbitration AwardCollective Bargaining AgreementTrust FundsDelinquent ContributionsRes JudicataManifest Disregard of LawScope of Judicial ReviewLabor Dispute
References
12
Case No. MISSING
Regular Panel Decision
Mar 03, 2015

Gesualdi v. Seacoast Petroleum Products, Inc.

Plaintiffs, the Trustees and Fiduciaries of various Local 282 Welfare, Pension, Annuity, Job Training, and Vacation and Sick Leave Trust Funds, initiated an action against Seacoast Petroleum Products, Inc. to recover unpaid liabilities and contributions. This action arose from two audits that identified delinquent contributions and the defendant's complete withdrawal from the Funds. Following Seacoast Petroleum Products, Inc.'s default, the Plaintiffs moved for a default judgment. United States Magistrate Judge Steven I. Locke recommended granting the motion and awarding specific damages. District Judge Spatt subsequently adopted the Report and Recommendation in its entirety, granting the default judgment and ordering damages totaling $156,898.74, along with daily interest, liquidated damages, audit fees, attorneys' fees, and costs.

Default JudgmentERISAUnpaid ContributionsWithdrawal LiabilityEmployee BenefitsMulti-employer PlansCollective Bargaining AgreementTrust AgreementPrejudgment InterestLiquidated Damages
References
48
Case No. ADJ581749 (VNO 0529719)
Regular
Jul 02, 2012

ARLENE HITE vs. TEPCO (STANDARD ABRASIVES, INC.), EVEREST NATIONAL INSURANCE COMPANY, CLARENDON NATIONAL INSURANCE COMPANY

This case concerns Clarendon National Insurance Company's petition for reconsideration of an arbitrator's contribution award. Clarendon argued it should not be liable for contribution because it was joined as a defendant over a year after the underlying cumulative trauma claim was settled. The Board denied reconsideration, finding that Clarendon received timely actual notice of Everest's contribution claim within one year of the settlement approval. Therefore, despite the delay in formal joinder, Clarendon cannot show prejudice and is liable for its share of the contribution award.

Workers' Compensation Appeals BoardPetition for ContributionLabor Code section 5500.5Cumulative traumaCompromise and releaseOrder of JoinderNunc pro tuncActual noticeTimely noticePrejudice
References
0
Case No. 01-15-00147-CV
Regular Panel Decision
Apr 06, 2015

Metropolitan Insurance and Annuity Company and Metropolitan Life Insurance Company v. Peachtree Settlement Funding, LLC

This case involves an appeal by Metropolitan Life Insurance Company and Metropolitan Insurance & Annuity Company (Appellants) against Peachtree Settlement Funding, LLC and Sara Swain (Appellees) regarding a trial court's approval of a structured settlement payment rights transfer. Sara Swain, the payee, sought to transfer partial monthly payments to Peachtree, leading to a "Servicing Arrangement" approved by the trial court. This arrangement allowed Peachtree to receive the full monthly payments, retain its assigned portion, and remit the remainder to Swain, without requiring MetLife to directly divide payments. MetLife challenged this, asserting the arrangement improperly modified contracts, contravened the Texas Transfer Statute, and imposed an involuntary business relationship. The Appellee's brief argues for the affirmation of the trial court's decision, emphasizing the legality of the servicing arrangement under Texas's principles of contract assignability and principal-agency law, and affirming the transfer as being in Swain's best interest.

Structured SettlementPayment Rights TransferServicing ArrangementContract AssignabilityPrincipal-Agency LawBest Interest DeterminationAppellate ReviewTexas Transfer StatuteLegal PrecedentAnnuity Issuer Obligations
References
68
Case No. MISSING
Regular Panel Decision

Trustees of the Mason Tenders, District Council Welfare Fund, Pension Fund, Annuity Fund & Training Program Fund v. Faulkner

Plaintiffs, comprised of Trustees of Mason Tenders District Council Welfare, Pension, Annuity, and Training Program Funds, and the Mason Tenders District Council of Greater New York, initiated legal action against Thomas Faulkner d/b/a American Demolition and Thomas Faulkner individually. The suit, filed under ERISA and the Taft-Hartley Act, alleged the defendants failed to allow an audit of their records and did not make required contributions to the plaintiff funds as stipulated by a collective bargaining agreement. Following a default judgment, Magistrate Judge Kevin Nathaniel Fox issued a Report and Recommendation. Plaintiffs objected to portions of this report, specifically regarding Faulkner's personal liability and the awarded attorneys' fees. Upon de novo review, District Judge Holwell modified the Report, determining that Faulkner was personally liable for the business's debts and awarding the full amount of attorneys' fees requested by the plaintiffs, totaling $6,588.75.

ERISATaft-Hartley ActEmployee BenefitsPension FundsWelfare FundsCollective BargainingAudit DisputesDefault JudgmentPersonal LiabilitySole Proprietorship
References
18
Case No. 1:06-CV-1034
Regular Panel Decision

Rahm v. Halpin (In Re Halpin)

This case involves an appeal from the United States Bankruptcy Court regarding the dischargeability of debt owed by William C. Halpin, Jr. (Appellee) to benefit funds of the International Brotherhood of Electrical Workers Local 236 (Plaintiff-Appellants). The Plaintiff-Appellants alleged that Appellee, as president of Halpin Mechanical & Electric, Inc. (HM & E), breached his fiduciary duty by failing to remit employer contributions totaling $44,452.24 from July 2002 through January 2003. They sought to have this debt declared non-dischargeable under 11 U.S.C. § 523(a)(4) and to offset it with Appellee's annuity and pension benefits. The District Court reviewed the Bankruptcy Court's decision de novo. The central issues were whether the unremitted employer contributions constituted 'plan assets' and if Appellee acted in a fiduciary capacity regarding these funds. The Court found that the collective bargaining agreement (CBA) did not define when contributions became plan assets but rather implied they were contractual payment obligations. Consequently, Appellee was deemed not to have fiduciary responsibilities over these specific unpaid employer contributions. Although Appellee admitted breaching fiduciary duty concerning contributions withheld from employee pay (which are considered plan assets), these specific debts were resolved separately. Since the unpaid employer contributions were not considered plan assets, Appellee was found to have no personal liability for them under a fiduciary capacity, rendering the debt dischargeable. Furthermore, the Court determined that an offset against Appellee's benefits was unavailable. Therefore, the District Court affirmed the Bankruptcy Court's order, concluding that the debt arising from the unremitted employer contributions was dischargeable.

Bankruptcy LawFiduciary DutyERISAPlan AssetsEmployer ContributionsDebt DischargeabilitySetoffCollective Bargaining AgreementAppellate ReviewBenefit Funds
References
17
Case No. MISSING
Regular Panel Decision

Smith v. Local Union 28 Sheet Metal Workers

Plaintiff Wayne Smith, acting pro se, sued Sheet Metal Workers’ Local Union No. 28 (Local 28), its Joint Apprenticeship Committee (JAC), and several individuals and a company, alleging race discrimination under Title VII, 42 U.S.C. §§ 1981, 1985, and breach of duty of fair representation under the Labor Management Relations Act. Smith claimed improper wage payments, withheld annuity contributions, discriminatory termination, and referral to a counseling program. The court found that Smith failed to establish a prima facie case of racial discrimination, as evidence showed he was treated similarly to other apprentices regarding wages, annuity contributions, and program advancements. Additionally, his Title VII claims were time-barred, and some defendants were not named in administrative charges, failing the "identity of interest" exception. The claims for breach of fair representation were also dismissed due to being outside the six-month statute of limitations and lacking evidence of arbitrary, discriminatory, or bad faith conduct by the union. Therefore, the defendants' motions for summary judgment were granted.

Employment DiscriminationRace DiscriminationTitle VIISection 1981Section 1985Labor Management Relations ActDuty of Fair RepresentationSummary JudgmentApprenticeship ProgramStatute of Limitations
References
33
Case No. MISSING
Regular Panel Decision

Sciascia v. Rochdale Village, Inc.

The Trustees of the Special and Superior Officers Benevolent Association Defined Contribution Fund (Plaintiffs) sued Rochdale Village, Inc. (Defendant) for allegedly failing to make required contributions to the fund. The Plaintiffs' claims were brought under Section 301 of the LMRA and Sections 515 and 502(a)(3) of ERISA. The Defendant argued that its obligation was contingent on an unsatisfied condition precedent and that the contributions would be illegal under LMRA Section 302. The Court found the Memorandum of Agreement created an unambiguous obligation for the Defendant to contribute, and the SSOBA Fund did not violate LMRA Section 302. Therefore, the Court granted the Plaintiffs' motion for summary judgment and denied the Defendant's motion.

ERISALMRACollective Bargaining AgreementDefined Contribution PlanPension FundSummary JudgmentCondition PrecedentMultiemployer PlanTrust FundEmployer Contributions
References
50
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