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

Background

On March 31, 2025, the petitioners filed a petition under Section 301 of the Labor Management Relations Act to confirm an arbitration award issued on December 6, 2024. The petitioners served JH Shades & Draperies Inc. with the petition, supporting documents, the award, and their supporting memorandum. The court ordered JH Shades to respond by May 29, 2025. JH Shades did not respond or seek relief from the award.

The arbitrator reviewed the collective bargaining agreement, supporting documents, and evidence and testimony from a November 12, 2024 hearing. The arbitrator determined that JH Shades was bound by the collective bargaining agreement effective July 21, 2022; that the agreement required contributions to the petitioners’ fringe-benefit trust funds; and that an audit showed unpaid contributions for July 21, 2022, through December 29, 2023. After JH Shades was notified of the delinquencies, it did not remit the required contributions. The arbitrator calculated damages under the collective bargaining agreement and the petitioners’ collection policy.

Legal Standard

The Federal Arbitration Act provides the governing law for confirming the award. Courts give substantial deference to arbitrators and generally do not review the merits of an arbitrator’s factual findings, contract interpretation, or remedies. The court’s review focuses on whether the award draws its authority from the collective bargaining agreement. Even when a petition is unopposed, the court must examine the petitioners’ submissions to determine whether they show that no genuine dispute of material fact prevents judgment in their favor. The court treated the petition as similar to a motion for summary judgment, which asks whether the undisputed record requires judgment for the moving party.

Court’s Analysis

The court found that the petitioners met their burden. The arbitrator’s decision provided more than the minimal justification required for confirmation, and the court found no basis under Section 10(a) of the Federal Arbitration Act to vacate the award. The court therefore confirmed the entire award.

The court also considered interest. The collective bargaining agreement made the arbitrator’s decision final and binding, and the collection policy specified interest for delinquent contributions at the prime lending rate of JPMorgan Chase Bank plus 200 basis points. The arbitrator calculated that rate as 10.50% and awarded post-award interest at that rate. The court awarded prejudgment interest at 10.50% from the award date until entry of judgment.

The court awarded the petitioners’ requested attorneys’ fees and costs because JH Shades had not appeared and had provided no justification for failing to remit the contributions required by the arbitrator. The court also awarded post-judgment interest at the statutory rate under 28 U.S.C. § 1961(a).

Disposition

The court granted the petition, confirmed the December 6, 2024 arbitration award in all respects, and entered judgment for the petitioners and against JH Shades. The judgment awarded $54,182.27 under the award; $3,740.80 in post-award prejudgment interest; $1,648 in attorneys’ fees; $119.50 in costs; and post-judgment interest at the statutory rate. The Clerk of Court was directed to terminate pending motions and close the case.