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

Background

The petitioners included trustees of labor-management trust funds organized under the Employee Retirement Income Security Act, trustees of a charitable fund, a not-for-profit corporation, and a labor organization. Arbris Corp. was a New York employer and a member of the Building Contractors Association. Through that membership, Arbris agreed to be bound by agreements between the association and the New York City District Council of Carpenters.

Those agreements required Arbris to contribute to the petitioners’ funds. The petitioners alleged that Arbris failed to make required contributions from April 8, 2019, through October 6, 2019. They invoked the agreements’ arbitration provisions, and an arbitrator awarded the petitioners $90,327.87.

Arbris was served with the petition to confirm the award but never appeared or responded. The petitioners asked the court to treat the petition as an unopposed motion for summary judgment.

Legal standard

The petitioners sought confirmation under Section 301 of the Labor Management Relations Act, 29 U.S.C. § 185. The court explained that judicial review of a labor arbitration award is very limited. A court generally confirms an award when the arbitrator was at least arguably interpreting and applying the parties’ contract, acted within the scope of the arbitrator’s authority, and did not disregard the contract’s plain language. An award may not be confirmed if it was obtained through fraud or dishonesty.

The court also explained that an unopposed petition to confirm an arbitration award is generally treated like a summary-judgment motion, rather than as a request for a default judgment. The court may accept undisputed facts in the petition and record, but must still determine whether those facts establish the petitioners’ entitlement to judgment as a matter of law.

Ruling

The court found that the agreements required Arbris to make the contributions, that the petitioners properly arbitrated the dispute, and that the arbitrator acted within the arbitrator’s authority. The record did not suggest that the award was obtained through fraud or dishonesty. The court found no material factual dispute preventing confirmation and granted summary judgment in favor of the petitioners.

The court confirmed the arbitration award in all respects. The award consisted of $71,641.06 in principal deficiencies, $1,568.35 in interest, $14,328.21 in liquidated damages, $390.25 in promotional-fund contributions, $400 in court costs, $1,500 in attorneys’ fees, and $500 in arbitrator’s fees. The court also confirmed 7.5% annual interest on the award from the date of the award through the date of judgment.

Because the agreements allowed recovery of reasonable attorneys’ fees and costs incurred in the confirmation case, the court additionally awarded $1,189, consisting of $1,119 in attorneys’ fees and $70 in costs. Post-judgment interest would accrue at the statutory rate under 28 U.S.C. § 1961. The court requested that the Clerk close the case.