Olivieri v. P.M.B. Construction, Inc.
The Trustees of Suburban New York Regional Council of Carpenters Welfare, Pension, Vacation, Annuity, Apprentice Training and Charitable Trust Funds sued Syngen Group Corp. and Premier Staffing Solutions of Northeast Corp. for unpaid employee fringe benefit contributions under ERISA. The plaintiffs argued that the Premier Defendants, who leased carpentry employees to the PMB Defendants, were 'joint employers' and therefore jointly and severally liable. The Premier Defendants countered that as non-signatories to the collective bargaining agreements, they were not obligated to contribute. The Court denied the plaintiffs' motion for summary judgment and granted the Premier Defendants' motion, ruling that joint employer status alone, absent a direct contractual obligation, fraud, or alter ego relationship, is insufficient to impose ERISA liability on a non-signatory.