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

Background

The petitioners were jointly trusteed employee-benefit funds and The Carpenters Contractor Alliance of Metropolitan New York. They petitioned under Section 301 of the Labor Management Relations Act to confirm an arbitration award against Mint Maintenance LLC.

Mint Maintenance performed one day of work at Barclays Center in Brooklyn, New York. A project agreement bound it to a collective bargaining agreement with the New York City District Council of Carpenters. The agreement required Mint Maintenance to make contributions to the Funds for covered employee hours and permitted the Funds to audit the company’s books and records.

The Funds attempted to conduct an audit beginning June 23, 2023, but Mint Maintenance did not comply. The Funds then performed an estimated audit, which calculated unpaid contributions of $5,397.67. The Funds initiated arbitration before Jeffrey G. Stein. After a December 12, 2024 hearing, the arbitrator awarded $9,796.94, including the estimated contributions, interest through the hearing date, liquidated damages, suit costs, attorneys’ fees, and the arbitrator’s fee. The arbitrator also ordered Mint Maintenance to produce books and records so the audit could proceed. The award provided for interest at an annual rate of 10.5% from the date of the award.

Court’s analysis

The court treated the unopposed petition like a motion for summary judgment, meaning it reviewed the petition and supporting evidence to determine whether any material factual dispute required a trial. Review of a labor-arbitration award is highly deferential. The court stated that it could not reconsider the arbitrator’s factual or legal conclusions and instead had to determine whether the arbitrator acted within the authority granted by the collective bargaining agreement.

The court found that the petition and supporting materials satisfied the requirements for confirmation. It determined that it had subject-matter jurisdiction under Section 301 of the Labor Management Relations Act, that venue was proper, and that it had personal jurisdiction over Mint Maintenance. It also found that the arbitrator had authority under the collective bargaining agreement and the Funds’ collection policy.

The court separately considered the Funds’ request for attorneys’ fees and costs. It found reasonable the requested $1,504.70 in attorneys’ fees for 4.7 hours of work and accepted invoices supporting $323.85 in service costs.

Disposition

The court granted the petition and confirmed the award. The Clerk was directed to enter judgment confirming the award in all respects and awarding the Funds $9,796.94, plus 10.5% annual interest from December 12, 2024; $323.85 in costs; $1,504.70 in attorneys’ fees; and post-judgment interest at the statutory rate. The court also directed the Clerk to close the action.