Trustees Of The New York City District Council Of Carpenters Pension Fund v…

Background

The Funds petitioned under Section 301 of the Labor-Management Relations Act to confirm an arbitration award against MAC Installations LLC. The dispute arose under a collective-bargaining agreement between MAC and the New York City District Council of Carpenters. The agreement required MAC to make contributions to the Funds for certain employee work and allowed the Funds to audit MAC’s records.

An audit covering June 19, 2021 through December 22, 2023 found that MAC had not remitted $47,116.91 in required contributions. The dispute went to arbitration before J.J. Pierson. MAC appeared at the arbitration hearing, did not contest liability, but questioned the amount. On December 4, 2024, the arbitrator ordered MAC to pay $83,440.24, consisting of the principal deficiency, interest, liquidated damages, promotional fund contributions, late-payment interest, court costs, attorneys’ fees, arbitrator’s fees, and audit costs. The award also required 10.5% annual interest from the award date through entry of judgment.

MAC did not comply with the award. The Funds filed this petition on March 28, 2025. MAC did not respond, and the court stated that it would consider the petition unopposed.

Legal standard

The court explained that review of a labor arbitration award is very limited. A court generally must confirm an award if the arbitrator was interpreting and applying the collective-bargaining agreement and acted within the authority granted by that agreement, absent exceptional circumstances such as fraud or a violation of public policy.

Because an unanswered petition to confirm an arbitration award is treated as an unopposed motion for summary judgment, the court had to determine whether the undisputed facts showed that the Funds were entitled to judgment as a matter of law. Summary judgment is a procedure for entering judgment when there is no genuine dispute about an important fact.

Court’s analysis

The court found no genuine issue of material fact. It also found no indication that the award was obtained through fraud or dishonesty, that Arbitrator Pierson disregarded the collective-bargaining agreement, or that he acted outside the scope of his authority. The record showed that the arbitrator relied on undisputed evidence that MAC failed to report all hours worked and therefore failed to make required contributions. The amounts awarded were based on the collective-bargaining agreement and related agreements.

The court therefore confirmed the award in all respects. It also granted the request for post-judgment interest and awarded the Funds interest at 10.5% annually from December 4, 2024 through the date judgment was entered.

Attorneys’ fees and costs

The Funds requested attorneys’ fees and costs for the federal proceeding. The court found the requested fees and costs fair and reasonable based on the billing records, counsel’s experience, and rates approved in similar cases. The court approved $1,607 in attorneys’ fees and $151.60 in costs.

Disposition

The petition was GRANTED. The Clerk was directed to enter judgment for the Funds and against MAC as follows: confirmation of the December 4, 2024 arbitration award; $83,440.24 plus 10.5% annual interest through entry of judgment; $151.60 in proceeding-related costs; and $1,607 in proceeding-related attorneys’ fees. Statutory post-judgment interest under 28 U.S.C. § 1961 was ordered from entry of judgment until payment in full.