Holland v. Valley Services, Inc., 845 F. Supp. 2d 220

Plaintiffs are trustees of the United Mine Workers of America 1992 Benefit Plan seeking recovery from Valley Services, Inc. and related entities under the Coal Act and ERISA.
The court had previously granted in part and denied in part the parties’ cross-motions for summary judgment and ordered supplemental briefing on damages.
Valley Services operated a coal mine (1962–1979); it dissolved; Ovila Bibeau and Dorothy Kilbourne became owners; Bibeau Construction related to Valley Services.
Employee Marcum was injured in 1979; in 1995 his retiree health benefits were approved; plan paid medical costs dating back to February 1, 2003.
In 2004 the plan notified Bibeau Construction it was related to Valley Services and jointly liable for premiums; further delinquency notices followed in 2005.
Plaintiffs filed suit in February 2006; damages briefing followed after partial summary judgment; court now alters its calculation of the applicable statute of limitations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Proper limitations framework for multiemployer funds	Holland argues Bay Area Laundry framework governs timing.	Valley contends the prior framework should apply.	Bay Area Laundry framework governs.
Timeliness of claims under Bay Area Laundry	Complaint filed Feb 1, 2006; claims timely for payments after Feb 1, 2000.	Claims time-barred for earlier payments.	Claims timely for payments missed on or after February 1, 2000.
Scope of damages briefing required	Damages to be determined with updated briefing.	Damages can be calculated with existing record.	Further damages briefing required; precise amount to be determined after briefing.

Bay Area Laundry & Dry Cleaning Pension Trust Fund v. Ferbar Corp. of Cal., Inc., 522 U.S. 192 (U.S. Supreme Court 1997) (each missed payment under a multiemployer pension fund creates a separate six-year limitation period)