Knall Beverage, Inc. v. Teamsters Local Union No. 293 Pension Plan
744 F.3d 419
6th Cir.2014Background
- Three employers formerly contributing members of Teamsters Local Union No. 293 Pension Plan dispute district court dismissal under the Multiemployer Pension Plan Amendments Act (ERISA).
- Withdrawal from the plan triggered withdrawal liability; the plan then contemplates reallocation liability if a mass withdrawal occurs within three years.
- In 2007–2008, each plaintiff agreed to terminate its individual membership and paid or is paying withdrawal liability; plaintiffs now challenge post-withdrawal reallocation liability.
- In 2009 trustees determined a mass withdrawal by others terminated the fund; plaintiffs allegedly triggered reallocation liability by zipper clauses allowing withdrawal if others withdrew.
- Arbitration under 29 U.S.C. § 1401 is mandatory for disputes about reallocation liability; plaintiffs filed civil action seeking relief from such liability, and arbitration was stayed pending this suit.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether arbitration is mandatory for reallocation liability disputes. | Plaintiffs argue § 1392(c) precludes arbitration by invalidating mass withdrawal. | Defendants contend arbitration is required under § 1401(a)(1) for disputes under §§ 1381–1399. | Arbitration required; suit dismissed without prejudice. |
| Whether mass withdrawal validity is arbitrable and central to liability. | Plaintiffs claim mass withdrawal is sham and not subject to arbitration. | Defendants argue disputes about withdrawal and liability fall under arbitration anyway. | Disputes over reallocation liability are arbitrable; mass-withdrawal validity issues are intertwined with § 1392 determinations and arbitrable. |
| Whether there is a non-arbitration exception to arbitration for this case. | Plaintiffs seek a direct federal forum based on exceptions to arbitration. | Defendants rely on no applicable exceptions beyond statutory duty to arbitrate. | No exception applies; arbitration required. |
| Whether due process concerns negate the arbitration requirement. | Plaintiffs argue due process objections exist. | Defendants contend due process issues may be raised in § 1401(b)(2) review of arbitration. | Due process arguments not addressed on appeal; can be raised in later review. |
Key Cases Cited
- Mason & Dixon Tank Lines, Inc. v. Cent. States, S.E. & S.W. Areas Pension Fund, 852 F.2d 156 (6th Cir. 1988) (arbitration to resolve withdrawal-liability disputes)
- Trustees of Colo. Pipe Indus. Pension Trust v. Howard Elec. & Mech. Inc., 909 F.2d 1379 (10th Cir. 1990) (arbitration mandatory for withdrawal-related determinations)
- Teamsters Pension Trust Fund-Bd. of Trustees of W. Conference v. Align Transp. Co., 832 F.2d 502 (9th Cir. 1987) (tribunal arbitral route preferred for withdrawal-liability disputes)
- Findlay Truck Line, Inc. v. Cent. States, S.E. & S.W. Areas Pension Fund, 726 F.3d 738 (6th Cir. 2013) (three exceptions to arbitrate; this case discusses arbitration posture)