Findlay Truck Line, Inc. v. Central States, Southeast & Southwest Areas Pension Fund

Summarized by J. Debbeler , Bricker Graydon LLP
12 years 6 months ago

Citation:

12-3450; 12-3531

Tag(s):

Ruling:

The Sixth Circuit reversed the district court's injunctive order and affirmed the dismissal of a labor dispute governed by the Multiemployer Pension Plan Amendments Act of 1980 (MPPAA). The appellate court reversed the injunction based on the plain language of the MPPAA because (1) clearly-worded statutes have the power to divest courts of their equity powers and the MPPAA language is unequivocal and "pay now, dispute later" is established by two different provisions and (2) a more specific provision takes precedence over a more general one and the federal statutes governing withdrawal liability disputes arising under the MPPAA control over the Federal Rules of Civil Procedure and the Judiciary Act which grant equitable powers. The appellate court upheld the dismissal because Findlay failed to fall into one of three specific circumstances where arbitration is not required.

Procedural context:

An area pension fund (Fund) demanded that Findlay Truck Line (Findlay) pay 10 million dollars in pension liability to the Fund. Findlay filed an action in district court seeking declaratory and injunctive relief to prevent payment contending (1) that the withdrawal liability was improper because it occurred as the result of a labor dispute, (2) that despite an arbitration requirement in the MPPAA, Findlay should not be forced to arbitrate because the withdrawal was union-mandated and (3) that the interim payment requirement should not be upheld because Findlay would suffer irreparable harm if made to do so. The district court dismissed the case holding the MPPAA required the dispute to be arbitrated, but issued an injunction enjoining the Fund from collecting withdrawal liability payments pending arbitration because they would cause irreparable harm to Findlay. The Fund appealed the injunction and Findlay appealed the dismissal.

Facts:

Findlay is an Ohio corporation with fewer than 20 employees that participated in a multiemployer pension plan administered by the Fund. All employees are members of a union, which went on strike. During the strike, Findlay stopped making contributions to the Fund, but planned to resume once the strike ended. The Fund issued a notice that "your company may have withdrawn" from the Fund. The union notified Findlay that it "disclaimed" interest in the employees of Findlay and in response the Fund determined that Findlay's obligation to make pension contributions under the collective bargaining agreements ceased and thus Findlay had withdrawn from the Fund and issued a notice and demand for payment of withdrawal liability over 10 million dollars. Findlay filed the complaint in district court and the Fund filed a motion to dismiss.

Judge(s):

Suhrheinrich (author), Moore and Gibbons

ABI Membership is required to access the full summary. Please Sign In using your ABI Member credentials. Not a Member yet? Join ABI now - it is absolutely worth it!