Refined Sugars, Inc. v. Local 807 Labor-Management Pension Fund
This case involves Refined Sugars, Inc. (RSI) challenging a withdrawal liability claim brought by the Local 807 Labor-Management Pension Fund and its Board of Trustees under ERISA and MPPAA. RSI filed for a declaratory judgment, arguing it was not an 'employer' subject to such liability. The court analyzed the definition of 'employer' under ERISA Title IV and Title I, concluding that RSI did not meet the criteria, particularly regarding common control with the direct employer, Francrete Corporation. Additionally, the court rejected the application of common law criteria and the joint employer theory. Consequently, RSI's motion for summary judgment was granted, and the defendants' cross-motion was denied, finding RSI not liable for withdrawal contributions.