Trustees for The Mason Tenders District Council Welfare Fund v. JTL…

Background

The Trustees for the Mason Tenders District Council Welfare Fund, Pension Fund, Annuity Fund, and Training Program Fund, along with John J. Virga and Robert Bonanza, petitioned to confirm an arbitration award issued on October 16, 2018. JTL Construction Corp. did not appear in the case and did not oppose the petition.

JTL had entered into the Slow Food Market Lane Project Labor Agreement, which required it to comply with specified collective bargaining and trust agreements. Those agreements required JTL to make benefit-fund contributions and pay union dues. They also allowed claims for delinquent contributions to be submitted to arbitration and allowed an award of unpaid contributions, interest, liquidated damages, attorneys’ fees, and costs.

The arbitrator found that JTL was delinquent in making fringe-benefit and other contributions for the period from January 1, 2017, through June 30, 2017. After JTL did not appear at the October 15, 2018, arbitration hearing, the arbitrator issued an award finding that JTL owed $28,571.67 in delinquent fringe benefits and requiring JTL to pay $2,600 toward attorneys’ fees and the arbitration fee.

Court’s Analysis

The petition was brought under Section 301 of the Labor Management Relations Act. The court explained that an unanswered petition to confirm a labor-arbitration award is generally treated as an unopposed motion for summary judgment, which is a request for judgment when there is no genuine dispute over important facts.

The court emphasized that judicial review of labor-arbitration awards is highly deferential. A court may not overturn an award merely because it believes the arbitrator made a serious error, so long as the arbitrator was interpreting or applying the parties’ agreement and acted within the scope of the granted authority.

The court found no genuine dispute of material fact. It determined that the award was grounded in the parties’ agreement, which required JTL to make contributions to the trust funds and authorized arbitration and awards of money damages, interest, and attorneys’ fees. The court therefore concluded that the arbitrator acted within the agreement’s authority and that the award should be confirmed.

Ruling

The court granted the petition in full and confirmed the arbitration award. The court’s conclusion states that the petitioners were entitled to a total of $31,171.67, consisting of delinquent fringe contributions, dues and political-action-committee contributions, liquidated damages, attorneys’ fees, and arbitration fees.

The court also ruled that post-judgment interest would accrue on the entire amount from the date judgment was entered, at the rate provided by 28 U.S.C. § 1961. The Clerk of Court was directed to close the case.