Findlay Truck Line, Inc. v. Central States, Southeast & Southwest Areas Pension Fund
726 F.3d 738
| 6th Cir. | 2013Background
- Findlay Truck Line, a small Ohio employer covered by Central States multiemployer pension plan, stopped contributions after a 2011 labor dispute and union activity; the Fund declared Findlay withdrawn and demanded $10,164,531.55 in withdrawal liability.
- Findlay sued in federal court seeking declaratory and injunctive relief: (1) contesting the Fund’s withdrawal-liability assessment (including contesting the union disclaimer), (2) arguing it should not be compelled to arbitrate (claiming a "union-mandated" withdrawal or other exceptions), and (3) seeking to avoid making statutorily required interim payments as irreparably harmful.
- The district court dismissed the suit as pre-arbitration under the MPPAA and simultaneously enjoined the Fund from collecting interim payments pending arbitration, finding irreparable harm.
- The Fund appealed the injunction; Findlay cross-appealed the dismissal. The Sixth Circuit affirmed dismissal (ordered arbitration) but reversed the injunction, holding the MPPAA’s "pay now, dispute later" scheme divests courts of equitable authority to enjoin interim payments.
- Central legal tension: statutory MPPAA arbitration and interim-payment mandates (29 U.S.C. §§ 1399(c)(2), 1401(d)) versus a court’s equitable power to grant injunctive relief when interim payments would cause irreparable harm.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a court may enjoin statutorily required interim withdrawal payments under the MPPAA | Findlay: interim payments would cause irreparable harm, so equity should block collection | Fund: statute mandates interim payments; courts lack authority to enjoin them despite equitable concerns | Held: MPPAA’s clear text (§§ 1399(c)(2), 1401(d)) precludes equitable exceptions; injunction reversed |
| Whether "union-mandated" or labor-dispute circumstances exempt the dispute from arbitration | Findlay: unique "union-mandated" withdrawal and § 1398 labor-dispute protection justify judicial resolution | Fund: arbitration is mandatory under § 1401(a)(1); § 1398 applicability is for arbitrator to decide | Held: dismissal in favor of arbitration affirmed; § 1398 applicability reserved to arbitrator |
| Whether Sixth Circuit precedent (Mason & Dixon / Marvin Hayes) allows an equitable exception to "pay now, dispute later" | Findlay: reads Mason & Dixon to permit irreparable-harm exceptions | Fund: relies on Marvin Hayes as requiring interim payments | Held: neither case authoritatively creates an exception; statutory text controls; no equitable carve-out recognized |
| Procedural adequacy of district court injunction (hearings, bond, findings) | Findlay: injunction procedurally acceptable given harm | Fund: district court failed to give notice, hold evidentiary hearing, consider bond and make findings | Held: procedural errors noted but moot because court lacked jurisdiction to issue injunction under MPPAA |
Key Cases Cited
- Nachman Corp. v. Pension Benefit Guaranty Corp., 446 U.S. 359 (U.S. 1980) (ERISA’s purpose to secure promised pension benefits)
- Pension Benefit Guar. Corp. v. R.A. Gray & Co., 467 U.S. 717 (U.S. 1984) (background on PBGC and multiemployer plan distress leading to MPPAA)
- Marvin Hayes Lines, Inc. v. Cent. States, Se. & Sw. Areas Pension Fund, 814 F.2d 297 (6th Cir. 1987) (articulates the MPPAA’s "pay now, dispute later" policy and arbitration framework)
- Mason & Dixon Tank Lines, Inc. v. Cent. States, Se. & Sw. Areas Pension Fund, 852 F.2d 156 (6th Cir. 1988) (discusses arbitration supremacy; does not resolve interim-payment exception)
- Trustees of the Chicago Truck Drivers, Helpers & Warehouse Workers Pension Fund v. Cent. Transp., Inc., 935 F.2d 114 (7th Cir. 1991) (defense of interim-payment rule and rationale for congressional protection of funds)
- Galgay v. Beaverbrook Coal Co., 105 F.3d 137 (3d Cir. 1997) (reads MPPAA text to limit courts to ordering interim payments once statutory prerequisites are met)
- Grupo Mexicano de Desarrollos S.A. v. Alliance Bond Fund, Inc., 527 U.S. 308 (U.S. 1999) (limits on equitable injunctive powers where statute and law specify otherwise)
- United States v. Oakland Cannabis Buyers' Coop., 532 U.S. 483 (U.S. 2001) (statute can divest courts of equitable powers when clearly expressed)