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

Background

The petitioners were the trustees of several employee-benefit funds, the trustees of the New York City District Council of Carpenters Relief and Charity Fund, and the Carpenter Contractor Alliance of Metropolitan New York. The funds were parties to, or beneficiaries of, a collective bargaining agreement between AAA Windows & Doors Corporation and the New York City District Council of Carpenters. The agreement required covered employers to make contributions for covered employees and to provide records for audits.

The funds audited AAA’s records for December 8, 2019 through December 30, 2023. The audit calculated that AAA owed $75,774.94 in contributions, and AAA did not challenge the estimated findings. The funds then arbitrated the dispute before Daniel Engelstein. AAA received notice but did not appear at the December 5, 2024 arbitration hearing.

On December 6, 2024, the arbitrator found that AAA violated the collective bargaining agreement and awarded the petitioners $128,982.25. That amount included principal, interest, liquidated damages, promotional-fund contributions, late-payment interest, auditor’s fees, attorneys’ fees, and arbitration costs. The arbitrator also provided for 10.50% annual interest from the date of the award. AAA did not comply with the award.

Court’s analysis

The petitioners asked the court to confirm the arbitration award under Section 301 of the Labor Management Relations Act. The court explained that review of a labor arbitration award is very limited: the court generally does not reconsider the arbitrator’s interpretation of the dispute, but checks whether the arbitrator acted within the authority granted by the collective bargaining agreement and whether the award drew its basis from that agreement.

The petitioners’ confirmation request was unopposed because AAA did not appear or file papers after being served. The court nevertheless reviewed the petition and supporting evidence. It found no reason to believe that the award was obtained through fraud or dishonesty, that the arbitrator ignored the collective bargaining agreement, or that the arbitrator acted outside the assigned authority. The court also found that the award’s amounts were supported by relevant agreement provisions and undisputed testimony.

The court held that the petitioners were entitled to post-judgment interest under 28 U.S.C. § 1961. It also found an award of attorneys’ fees and costs justified because AAA had agreed to arbitration, had not complied with the award, and had offered no explanation for its failure to do so. The requested $3,925.50 in fees and $542.90 in costs were supported by billing records, and the court found the 13.4 hours and hourly rates reasonable.

Disposition

Judge Gregory H. Woods granted the petition to confirm the arbitration award. The court directed the Clerk to enter judgment for $128,982.25, plus prejudgment interest at 10.50% per year from December 6, 2024 through the judgment date, attorneys’ fees and costs totaling $4,468.40, and post-judgment interest at the statutory rate from entry of judgment until full payment.