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

Background

The petitioners—the trustees of several labor-management funds, the Trustees of the New York City Carpenters Relief and Charity Fund, and the Carpenter Contractor Alliance of Metropolitan New York—asked the court under Section 301 of the Labor Management Relations Act to confirm an arbitration award against J&V Locks and Doors, Inc. The opinion refers to these petitioners collectively as the “Funds.”

J&V was bound through a project labor agreement to collective bargaining agreements with the New York City District Council of Carpenters. Those agreements required J&V to make contributions for covered employees and allowed disputes about unpaid contributions to be resolved through arbitration. An audit covering November 2020 through March 2023 found that J&V had not paid all required contributions. After J&V failed to pay the shortfall, the Funds initiated arbitration.

The arbitrator issued an award on June 24, 2024, requiring J&V to pay $2,643.46 in unpaid contributions, $638.05 in accrued interest, $638.05 in liquidated damages, $4.48 in promotional fund contributions, $1,500 in attorneys’ fees, $2,885 in audit costs, $405 in court costs, and $1,000 in arbitration costs. The total was $9,714.04, with post-award interest at 10.5% per year. J&V did not appear in the federal case.

Legal standard

The court explained that federal courts give arbitration awards substantial deference, especially in labor disputes. An award generally must be confirmed if it has at least a minimally plausible basis in the parties’ agreement and the arbitrator acted within the authority granted by that agreement. The court also treated the unanswered petition as an unopposed motion for summary judgment, but still required the Funds to show that no genuine dispute of material fact existed.

Ruling

The court confirmed the arbitration award. It found that the Funds had shown there was no genuine dispute about the arbitration’s validity, that the arbitrator had provided more than the required minimal justification, and that no statutory basis existed to vacate or modify the award. The court also found that the parties’ agreements authorized arbitration of disputes involving unpaid contributions.

The court awarded the Funds $3,405 in attorneys’ fees for this federal action. It found that J&V had not paid the award or offered a justification for refusing to do so, and that the agreements allowed recovery of reasonable fees and costs. The court also approved $133.90 in costs for service and postage.

Because confirmation produced a money judgment in a civil case, the court awarded post-judgment interest at the statutory rate. In its conclusion, the court directed the Clerk to enter judgment against J&V for $9,714.04, plus 10.5% post-award interest accruing from June 24, 2024, through the date of judgment, $3,538.90 in attorneys’ fees and costs, and statutory post-judgment interest. The Clerk was also directed to terminate the motion and close the case. Judge Analisa Torres signed the order.