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

Background

The petitioners included trustees of multiemployer labor-management trust funds governed by the Employee Retirement Income Security Act (ERISA), trustees of the New York City Carpenters Relief and Charity Fund, the Carpenter Contractor Alliance of Metropolitan New York, and the New York City District Council of Carpenters. AAA Windows & Doors Corporation was bound to a project labor agreement and, through that agreement, to an applicable collective bargaining agreement with the New York City District Council of Carpenters.

The agreements required AAA to contribute to the petitioners’ funds. The petitioners alleged that AAA failed to make required contributions from April 12, 2018, through December 7, 2019. After the petitioners invoked the agreements’ arbitration provisions, an arbitrator awarded $26,992.96. The opinion identifies the award as including a principal deficiency, interest, liquidated damages, audit costs, promotional fund contributions, previous late-payment interest, a bond fee, court costs, attorneys’ fees, and the arbitrator’s fee, less a payment on account.

AAA was served with the petition on March 24, 2022, 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 Taft-Hartley Labor Management Relations Act, 29 U.S.C. § 185. The court explained that review of a labor arbitration award is very limited. A court generally must uphold the arbitrator’s factual findings, contract interpretation, and remedies unless the award was obtained through fraud or dishonesty, or the arbitrator was not at least arguably interpreting the contract or acted outside the arbitrator’s authority.

Because the petition was unopposed, the court treated the petition and supporting record like a motion for summary judgment. The court stated that an unopposed petition still must be supported by undisputed facts showing that the petitioners were entitled to judgment as a matter of law.

Court’s analysis

The court found that the agreements required AAA to contribute to the funds and that AAA failed to do so. It concluded that the arbitrator was applying the agreements and acting within the scope of the arbitrator’s authority. The unopposed record did not suggest that the award resulted from fraud or dishonesty, and no material factual dispute prevented confirmation.

The court also considered the petitioners’ request for fees and costs incurred in the confirmation proceeding. The applicable collective bargaining agreement provided for reasonable attorneys’ fees and costs. Based on counsel’s hourly accounting, the court found reasonable $1,017.50 in attorneys’ fees and $77 in costs, totaling $1,094.50.

Ruling

The court granted summary judgment in favor of the petitioners and confirmed the arbitration award in all respects. It additionally awarded $1,094.50 in attorneys’ fees and costs for the court proceeding. The court stated that post-judgment interest would accrue at the statutory rate, directed the Clerk to enter judgment under Rule 58(a) of the Federal Rules of Civil Procedure, and ordered the case closed.