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

Background

The petitioners were the trustees of several funds, the Carpenter Contractor Alliance of Metropolitan New York, and the New York City District Council of Carpenters. Statewide Restoration was bound by a project labor agreement and a collective bargaining agreement with the Union. Those agreements required Statewide Restoration to make contributions to the funds, permit audits, and submit certain payment disputes to arbitration. They also provided for interest, liquidated damages, attorneys’ fees, and costs in connection with unpaid contributions.

The petitioners audited Statewide Restoration’s books for August 17, 2017, through September 25, 2018, and determined that required contributions had not been fully paid. Arbitrator Roger E. Maher notified Statewide Restoration of the arbitration hearing, but Statewide Restoration did not appear. On July 30, 2019, Maher issued an award requiring Statewide Restoration to pay $91,069.93, consisting of delinquent contributions, interest, liquidated damages, late-payment interest, costs, and fees. After Statewide Restoration did not fully comply, the petitioners filed this action under Section 301 of the Labor Management Relations Act to confirm the award. Statewide Restoration did not formally oppose the petition or file documents in the case.

Confirmation of the Award

The court treated the unopposed request to confirm the award under the standards applicable to summary judgment. Summary judgment is appropriate when there is no genuine dispute about a material fact and the moving party is entitled to judgment as a matter of law. Even when a request is unopposed, the court must independently determine whether the supporting evidence meets that standard.

The court explained that review of an arbitration award is severely limited. A court generally must confirm an award unless it is vacated, modified, or corrected, and an award should be enforced if there is at least a barely reasonable justification for the result. Based on the award and the petitioners’ evidence, the court found no material factual dispute. It concluded that the arbitrator acted within the authority granted by the parties and relied on substantial and credible evidence that Statewide Restoration was required to make the payments and failed to do so. The court therefore confirmed the award in favor of the petitioners for $91,069.93.

Attorneys’ Fees and Post-Judgment Interest

The petitioners separately sought attorneys’ fees and costs incurred in bringing the confirmation action. The court held that Section 301 of the Labor Management Relations Act did not authorize that request. Although courts may award fees under their inherent equitable powers when an opposing party acts in bad faith, the petitioners had not provided evidence of bad faith. The court therefore did not award fees or costs associated with the petition.

The court awarded post-judgment interest beginning when judgment was entered and continuing until payment. It explained that federal law makes such interest mandatory on money judgments in civil cases and applies that rule to judgments confirming arbitration awards.

Disposition

Judge Paul A. Engelmayer confirmed the arbitration award and entered judgment for $91,069.93, plus post-judgment interest under 28 U.S.C. § 1961(a). The court did not award attorneys’ fees or costs associated with bringing the petition and requested that the clerk close the case.