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

Case No. MISSING
Regular Panel Decision

Textile Workers Pension Fund v. STANDARD DYE ETC.

The Textile Workers Pension Fund, a multiemployer pension plan, sued Standard Dye & Finishing Co. Inc. for withdrawal liability under the Multiemployer Pension Plan Amendments Act of 1980 (MPPAA). The Company ceased operations in June 1980, relying on the pre-MPPAA ERISA provisions that limited its liability. However, the MPPAA, enacted in September 1980, retroactively applied its stricter withdrawal liability rules to April 1980, leading to an assessment of nearly $1,000,000 against the Company. The Company moved for summary judgment, arguing that the retroactive application violated its Fifth Amendment due process rights. The Court denied the motion, finding that Congress acted rationally in making the MPPAA retroactive to address the serious financial risks posed by mass employer withdrawals from multiemployer pension plans.

Multiemployer Pension PlanERISAMPPAAWithdrawal LiabilityRetroactive ApplicationDue ProcessFifth AmendmentSummary JudgmentPension FundsEmployer Liability
References
7
Case No. MISSING
Regular Panel Decision

F.H. Cobb Co. v. New York State Teamsters Conference Pension & Retirement Fund

F.H. Cobb Co., a subsidiary of Super Food Services Inc., filed an action seeking a declaration of non-liability under the Multiemployer Pension Plan Amendments Act of 1980 (MPPAA) concerning withdrawal liability to the New York State Teamsters Conference Pension and Retirement Fund. The MPPAA retroactively imposed liability for employers withdrawing on or after April 29, 1980. F.H. Cobb had ceased its primary wholesale distribution business by March 8, 1980, and retained a minimal workforce for only phase-out activities until May 16, 1980, with final pension contributions in May 1980. The court analyzed whether this constituted a 'complete withdrawal' prior to the MPPAA's effective date, concluding that the phase-out work did not negate the earlier cessation of covered operations. Consequently, the court granted summary judgment for the plaintiffs, declaring F.H. Cobb's non-liability under the MPPAA's withdrawal provisions.

MPPAAwithdrawal liabilitymultiemployer pension plancessation of operationssummary judgmentretroactive legislationpension contributionsphase-out workemployer obligationsplan funding
References
9
Case No. MISSING
Regular Panel Decision

Sova Outerwear Corp. v. Trustees of Amalgamated Cotton Garment & Allied Industries Fund

Plaintiff Sova Outerwear Corporation moved for summary judgment against the Trustees of the Amalgamated Cotton Garment and Allied Industries Fund, challenging the constitutionality of the Multiemployer Pension Plan Amendments Act of 1980 (MPPAA). Sova argued MPPAA violated due process, operated retroactively, constituted a 'taking' of property, and infringed on Seventh Amendment rights by denying a jury trial. The defendant cross-moved for summary judgment to collect Sova's withdrawal liability. The court denied Sova's motion, upholding MPPAA's constitutionality based on consistent prior rulings. The court granted the defendant's motion, finding Sova liable for $65,249.48 plus interest, as Sova failed to object to the assessment or request arbitration within the statutory period, thus fixing its liability.

MPPAAERISAWithdrawal LiabilitySummary JudgmentConstitutional LawDue ProcessSeventh AmendmentMultiemployer Pension PlanPension FundsEmployer Liability
References
10
Case No. MISSING
Regular Panel Decision

Sibley, Lindsay & Curr Co. v. Bakery, Confectionery & Tobacco Workers International Union

Sibley, Lindsay and Curr Co. challenged the constitutionality of the Multiemployer Pension Plan Amendment Act of 1980 (MPPAA)'s retroactive withdrawal liability provisions. Sibley's had closed its bakery and withdrawn from a multiemployer pension fund on May 31, 1980, before the MPPAA was enacted on September 26, 1980, which made its withdrawal liability provisions retroactive to April 29, 1980, subjecting Sibley's to a $315,927.00 liability. The court applied the Nachman four-factor test to assess the due process implications of this retroactive application. It found that Sibley's reliance interest outweighed that of other parties, the new liability was drastically different from prior regulations, and imposing the burden retroactively was inequitable and lacked moderating provisions. Consequently, the court ruled that the retroactive application of MPPAA violated Sibley's Fifth Amendment due process rights, granting Sibley's motion for summary judgment and denying the defendants' cross-motions.

MPPAAERISAWithdrawal LiabilityRetroactive LegislationDue ProcessFifth AmendmentSummary JudgmentPension FundsConstitutional LawMultiemployer Plans
References
7
Case No. MISSING
Regular Panel Decision

Textile Workers Pension Fund v. Standard Dye & Finishing Co.

Plaintiff Textile Workers Pension Fund sued Defendant Standard Dye & Finishing Co., Inc. to collect withdrawal assessments under the Multiemployer Pension Plan Amendments Act of 1980 (MPPAA). Standard Dye ceased its primary business operations in June 1980, prior to the MPPAA's effective date of September 26, 1980, but retained a few employees for clean-up and dismantling work through October 1980, for whom pension contributions were made. The core legal issue is whether Standard Dye "completely withdrew" from the pension plan before September 26, 1980, which would eliminate liability due to the Tax Reform Act of 1984. The Court analyzed the meaning of "permanently ceases all covered operations" under 29 U.S.C. § 1383(a), considering similar precedents. The Court found that the retention of a skeleton crew for liquidation activities did not prevent a complete cessation of covered operations. Therefore, Standard Dye effected a complete withdrawal prior to the MPPAA's effective date.

Multiemployer Pension Plan Amendments ActWithdrawal LiabilityPension PlanComplete WithdrawalCovered OperationsTax Reform Act of 1984Retroactive ApplicationSummary JudgmentStatutory InterpretationCollective Bargaining Agreement
References
11
Case No. MISSING
Regular Panel Decision

A. Soloff & Son, Inc. v. Asher

A. Soloff & Son, Inc. challenged the constitutionality of the Multiemployer Pension Plan Amendments Act of 1980 (MPPAA) regarding withdrawal liability, alleging violations of the Fifth Amendment (due process and takings clause), the Seventh Amendment (right to a jury trial), and the Fifth Amendment's equal protection clause. The District Court for the Southern District of New York denied Soloff's motion for summary judgment, finding the MPPAA constitutional, consistent with Supreme Court and Circuit Court precedents. The court dismissed Soloff's complaint and granted the Fund's cross-motion for summary judgment, affirming Soloff's withdrawal liability due to failure to timely arbitrate.

MPPAAERISAWithdrawal LiabilityConstitutional LawFifth AmendmentSeventh AmendmentDue ProcessTakings ClauseEqual ProtectionSummary Judgment Motion
References
15
Case No. MISSING
Regular Panel Decision

Matter of Computerized Steel Fabricators, Inc.

The reorganized Chapter XI debtor, Computerized Steel Fabricators, Inc., initiated a motion to hold Pension Fund Iron Workers Local 455 in contempt. Computerized argued that its Chapter XI confirmation order discharged any potential withdrawal liability under the Multiemployer Pension Plan Amendments Act of 1980 (MPPAA), which the Pension Fund was attempting to collect post-confirmation. However, the court determined that Computerized's collective bargaining agreement was not rejected during bankruptcy and remained in effect, and thus the withdrawal liability arose in June 1982, post-confirmation, when Computerized ceased operations. The court held that this post-confirmation claim was not provable or dischargeable under the Bankruptcy Act and that the MPPAA's application was constitutional and not retroactive. Consequently, the application to hold the Pension Fund in contempt was denied.

BankruptcyChapter XIContemptMPPAAERISAWithdrawal LiabilityCollective Bargaining AgreementPost-confirmation ClaimsDischargeExecutory Contract
References
15
Case No. MISSING
Regular Panel Decision

Dorn v. Dorn's Transportation, Inc.

Walter Dorn, a New York resident, petitioned the U.S. District Court to confirm an arbitration award against Oneida Motor Freight, Inc., another New York corporation. The dispute arose from Oneida's refusal to pay the purchase price for Dorn's Transportation, Inc., alleging Dorn's failure to disclose union pension fund withdrawal liability under the Multiemployer Pension Plan Amendments Act of 1980 (MPPAA). Arbitrators ordered Oneida to pay Dorn $713,122.02. The court, presided over by Judge Kevin Thomas Duffy, dismissed Dorn's petition. The dismissal was based on a lack of subject matter jurisdiction, as the court determined that neither the Federal Arbitration Act itself nor arguments for interstate commerce or federal question jurisdiction via MPPAA interpretation provided an independent basis for federal jurisdiction, given the lack of diversity of citizenship among the parties.

JurisdictionFederal Arbitration ActSubject Matter JurisdictionArbitration Award ConfirmationInterstate CommerceFederal Question JurisdictionMultiemployer Pension Plan Amendments ActContract DisputeDiversity JurisdictionWell-Pleaded Complaint Rule
References
12
Case No. 92 Civ. 3728 (PKL), 92 Civ. 3781 (PKL)
Regular Panel Decision

Bowers v. Andrew Weir Shipping, Ltd.

This case arises under the Employee Retirement Income Security Act of 1974 (ERISA) and the Multiemployer Pension Plan Amendments Act of 1980 (MPPAA), focusing on withdrawal liability. The New York Shipping Association-International Longshoreman’s Association Pension Trust Fund (the Fund) sought to confirm an arbitrator's award against Andrew Weir Shipping, Ltd. and South African Marine Corp., Ltd. (collectively, Bank Line and Safmarine) for withdrawal obligations after they formed a joint venture, Safbank. Bank Line and Safmarine countered by seeking to vacate the award and moved for summary judgment, arguing various exemptions from liability and that they were not statutory 'employers.' The District Court affirmed the arbitrator's findings, denying all motions by Bank Line and Safmarine. The court held that the formation of Safbank did not qualify for MPPAA's corporate reorganization or sale of assets exemptions and upheld the broad definition of 'employer' as established in prior Second Circuit precedent.

ERISAMPPAAMultiemployer Pension PlanWithdrawal LiabilityArbitrator's AwardCorporate ReorganizationJoint VentureSale of Assets ExemptionDefinition of EmployerControlled Group
References
25
Case No. MISSING
Regular Panel Decision

New York State Teamsters Conference Pension & Retirement Fund v. St. Lawrence Transit Mix Corp.

This case involves a dispute under the Multiemployer Pension Plan Amendments Act (MPPAA) between the New York State Teamsters Conference Pension and Retirement Fund (Fund) and St. Lawrence Transit Mix Corp. (St. Lawrence) regarding withdrawal liability. St. Lawrence, after being acquired by Torrington Industries, failed to make withdrawal liability payments and did not timely initiate arbitration as required by 29 U.S.C. § 1401(a). The defendant moved to stay the action and compel arbitration, challenging the constitutionality of the MPPAA's presumptions and arguing that the absence of formal PBGC arbitration regulations negated its obligation. St. Lawrence also contended it was exempt under the "Sale of Assets" provision, 29 U.S.C. § 1384. The court denied the defendant's motion and granted the plaintiff's cross-motion for summary judgment, finding that St. Lawrence's failure to timely arbitrate fixed its liability and that its constitutional and statutory construction arguments were without merit.

Withdrawal LiabilityMPPAAERISASummary JudgmentArbitrationPension PlanMultiemployer FundSale of AssetsStatutory ConstructionDue Process
References
7
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