Trustees of the New York City District Council of Carpenters Pension Fund v…

Background

The petitioners included trustees of several employee-benefit funds organized under 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. ARS Office Furniture Installers Inc. had agreed to be bound by labor agreements with the District Council. Those agreements required ARS to contribute to the petitioner funds and to make its books and payroll records available for an audit concerning benefit contributions.

The petitioners sought confirmation of an arbitration award arising from ARS’s failure to permit an audit of its books and records for the period beginning June 30, 2019. ARS was served with the petition on October 29, 2021, but never appeared or responded. The petitioners asked the court to treat the petition as an unopposed motion for summary judgment.

Legal standard

Under Section 301 of the Labor Management Relations Act, a court’s review of a labor arbitration award is very limited. The court generally confirms an award if the arbitrator was at least arguably interpreting or applying the parties’ contract and acted within the arbitrator’s authority, unless the award was obtained through fraud or dishonesty. When a confirmation petition is unopposed, the court treats the petition and supporting record like a motion for summary judgment. The court may accept undisputed facts, but must still determine whether those facts establish entitlement to judgment as a matter of law.

Court’s analysis and ruling

The court found that the agreements required ARS to provide its books and records for an audit. After ARS failed to do so, the petitioners invoked the agreements’ arbitration provisions. Following a hearing, the arbitrator found that ARS violated the agreements and ordered ARS to produce its books and records for the audit. The arbitrator also awarded $2,900, consisting of $1,500 in attorneys’ fees, a $1,000 arbitrator’s fee, and $400 in court costs.

The court found that the arbitrator was applying the agreements and acting within the scope of the arbitrator’s authority. The unopposed record did not suggest fraud or dishonesty. The court therefore treated the petition as an unopposed motion for summary judgment and granted summary judgment in favor of the petitioners. It confirmed the arbitration award in all respects.

The court also found that the agreements entitled the petitioners to reasonable attorneys’ fees and costs incurred in the court action. It additionally awarded $1,562, consisting of $1,485 in attorneys’ fees and $77 in costs. Post-judgment interest will accrue at the statutory rate. The court directed the Clerk to enter judgment under Rule 58(a) of the Federal Rules of Civil Procedure and close the case.