Spillane v. New York City District Council of Carpenters and Joiners of America

Background

Patrick Brendan Spillane and Debra Spillane sued the New York City District Council of Carpenters and Joiners of America (the “Union”), Eddie McWilliams, the New York City District Council of Carpenters Pension Fund, the New York City District Council of Carpenters Welfare Fund, Joseph A. Geiger, and Kristin O’Brien. The opinion refers to the Funds, Geiger, and O’Brien as the “Fund Defendants,” and the Union and McWilliams as the “Union Defendants.”

Spillane was a retired Union member. After retirement, he worked as a project manager for Anfield Interiors, Inc., which the complaint described as a non-union construction company. The Union investigated his work and charged him with violating the United Brotherhood of Carpenters and Joiners of America constitution by working as a foreman or supervisor for a non-union contractor. A Union trial occurred in Spillane’s absence, and he was found guilty. The Union later expelled him, and the Funds informed the plaintiffs that their pension and health benefits had been terminated.

The plaintiffs asserted claims under the Employee Retirement Income Security Act (ERISA) for denial of benefits and breach of fiduciary duty. Spillane separately asserted claims under the Labor-Management Reporting and Disclosure Act (LMRDA) concerning the Union’s disciplinary process and a state-law prima facie tort claim. The defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which tests whether a complaint states a legally sufficient claim. The plaintiffs moved for leave to file a second amended complaint.

ERISA Claims Against the Fund Defendants

The court granted the Fund Defendants’ motion to dismiss the ERISA denial-of-benefits claims. As to the pension plan, the court enforced a plan provision requiring an action to be filed within 365 days after notice of an adverse benefit determination. The plaintiffs received notice on January 17, 2020, but filed suit on September 27, 2021. The court concluded that the deadline was not unreasonably short and that the pension-benefit claims were time-barred.

As to the welfare plan, the court assumed without deciding that the 2003 Welfare Plan Summary Plan Description was the relevant plan. That plan gave the Welfare Fund’s trustees discretionary authority to interpret the plan and decide eligibility. Under the resulting arbitrary-and-capricious standard, the court would uphold the trustees’ decision unless it was without reason, unsupported by substantial evidence, or legally erroneous. The court held that the complaint did not plausibly show that the Funds’ interpretation—that Spillane’s work was disqualifying employment—failed that standard. The court therefore granted the motion to dismiss the welfare-benefit claim.

The court also granted the Fund Defendants’ motion to dismiss the ERISA fiduciary-duty claims. It held that the complaint did not allege sufficient facts showing that Geiger or O’Brien breached fiduciary duties. The allegations concerning Geiger were described as labels and conclusions, while the complaint largely stated only O’Brien’s position.

LMRDA Claims Against the Union Defendants

The court granted the Union Defendants’ motion to dismiss Spillane’s LMRDA claims. Spillane relied on the LMRDA provision requiring that a union member facing discipline receive specific written charges, reasonable time to prepare a defense, and a full and fair hearing.

The court held that the charge—working as a foreman for a non-union contractor since 2017—was sufficiently specific. It also held that the complaint did not adequately allege that Spillane lacked reasonable preparation time. Although the trial was allegedly moved from September to July and held while Spillane was away, the complaint did not allege that he lacked notice of the new date or explain why he lacked enough time to prepare.

The court likewise found that the complaint did not establish a full-and-fair-hearing violation. The complaint itself described witness testimony and documentary evidence presented at the Union trial. The court noted that the Union trial’s proceeding without Spillane raised a question about whether he had the opportunity to confront and cross-examine witnesses, but stated that those rights could be waived and that the record did not establish a waiver. Even if the complaint stated a hearing claim, however, the court held that Spillane had not exhausted internal Union remedies and had not shown that doing so would have been futile. The court also treated the LMRDA claim under 29 U.S.C. § 529 as abandoned because Spillane did not oppose the Union Defendants’ arguments concerning it.

Prima Facie Tort and Amendment

Because the federal claims were dismissed, the court declined to exercise supplemental jurisdiction—the federal court’s authority to hear related state-law claims—over Spillane’s prima facie tort claim. The court therefore denied the Union Defendants’ motion to dismiss that claim.

The court denied Plaintiffs’ motion for leave to file a second amended complaint. Plaintiffs acknowledged that the motion was untimely and proposed alleging that Spillane had never taken an oath under the Union constitution. The court held that Plaintiffs had not shown good cause for the late amendment and that the proposed amendment would be futile because it would not affect the ERISA claims and would not state a viable claim against the Union Defendants.

Disposition

Judge Torres ruled that the Fund Defendants’ motion to dismiss was granted as to the ERISA denial-of-benefits and fiduciary-duty claims. The Union Defendants’ motion to dismiss was granted in part and denied in part: it was granted as to Spillane’s LMRDA claims and denied as to his prima facie tort claim. Plaintiffs’ motion for leave to amend was denied. The opinion concludes that Plaintiffs’ claims were dismissed.