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

Background

The petitioners were trustees of employee benefit funds and the New York City District Council of Carpenters. They sued South Island Installers, Inc. under Section 301 of the Labor Management Relations Act of 1947 to confirm and enforce an arbitration award.

South Island Installers, Inc. was a member of the Association of Wall-Ceiling and Carpentry Industries of New York, Inc. The company had agreed to be bound by agreements between that Association and the Union. A collective bargaining agreement required the company to make contributions to the Funds for work within the Union’s trade and geographic jurisdiction.

After auditing the period from December 27, 2018, through March 31, 2021, the petitioners claimed that the company had not made all required contributions. The petitioners initiated arbitration. On March 22, 2022, Arbitrator Richard Adelman ordered South Island Installers, Inc. to pay the Funds $349,744.66. That amount included deficient contributions, interest, liquidated damages, late-payment interest, promotional fund contributions, and court, attorney, arbitration, and audit fees.

Court’s Analysis

The Federal Arbitration Act generally requires a court to confirm an arbitration award unless the award is vacated, modified, or corrected under the Act. The grounds for refusing confirmation are limited and include fraud, corruption, arbitrator bias, specified misconduct, exceeding the arbitrator’s authority, or a clear disregard of the law.

Although South Island Installers, Inc. did not appear or oppose the petition, the court still examined the petitioners’ materials to determine whether they met their burden. The court evaluated the petition under the legal standard used for summary judgment, which requires judgment when there is no genuine dispute over an important fact and the moving party is entitled to judgment under the law.

The court found no genuine dispute over any material fact. It also found that the collective bargaining agreement allowed the petitioners to seek arbitration for the company’s delinquency and that Arbitrator Adelman had not exceeded his authority. South Island Installers, Inc. presented no evidence supporting a basis to set aside the award.

Disposition

Judge J. Paul Oetken granted the petition to confirm the arbitration award. The Clerk of Court was directed to enter judgment for the petitioners in the amount of $349,744.66, plus $1,122 in attorneys’ fees, $77 in costs, and post-judgment statutory interest. The court also directed the petitioners to mail a copy of the order to South Island Installers, Inc. and directed that the case be closed.