Trustees for the Mason Tenders District Council Welfare Fund v. Construction

Background

The petitioners were the Trustees of four multi-employer funds and the Mason Tenders District Council of New York. Hilt Construction, Inc. was a construction contractor and a party to a project labor agreement with the Union. The agreement required covered employers to make contributions to jointly trusted employee-benefit funds at specified rates. It also allowed an employee representative to begin arbitration to collect delinquent contributions.

After an audit of Hilt’s books and records, a dispute arose over Hilt’s failure to make required fringe-benefit and other contributions. The petitioners initiated arbitration. Hilt received notice of the arbitration hearing but did not appear. The arbitrator found that Hilt had violated the labor agreement and directed it to pay the Funds $97,174.85. The award included delinquent contributions, dues and political-action-committee contributions, interest, liquidated damages, audit fees, attorneys’ fees, and arbitrator fees. Hilt did not pay the award.

The petitioners filed this action under Section 301 of the Labor Management Relations Act to confirm, or make enforceable as a court judgment, the arbitration award. Hilt was served but did not appear or respond.

Court’s Analysis

Because the petition was unopposed, the court treated it generally as an unopposed motion for summary judgment. The court nevertheless independently considered whether the petitioners showed that there was no genuine dispute of material fact and that they were entitled to judgment as a matter of law.

The court explained that judicial review of a labor arbitration award is highly deferential. The relevant question was whether the arbitrator acted within the authority granted by the parties’ agreement and at least arguably interpreted or applied that agreement. The court did not reconsider the arbitrator’s factual findings, reasoning, or assessment of the appropriate amount.

The court found that the parties had agreed to arbitrate disputes involving delinquent contributions. The arbitrator had interpreted the project labor agreement’s contribution requirements and found that Hilt owed delinquent fringe benefits and related amounts. Because the arbitrator acted within the scope of the authority granted by the agreement, the court confirmed the award.

Interest and Disposition

The petitioners also requested post-judgment interest under 28 U.S.C. § 1961. The court stated that such interest is mandatory and applies to actions confirming arbitration awards. It granted interest at the statutory rate from the date judgment was entered until payment was made.

The court granted the petition for confirmation of the award. It held that the Funds were entitled to $97,174.85, ordered statutory post-judgment interest, directed the Clerk of Court to enter judgment for the petitioners, and closed the case.