33 F.4th 424
7th Cir.2022Background
- RiverStone Group operated quarry sites and had a collective bargaining agreement with Local 150 that expired May 1, 2016.
- After expiration, RiverStone initially continued contract contributions; Local 150 struck on March 20, 2018, and RiverStone thereafter hired replacement/new employees and stopped contributing on their behalf.
- The Funds audited RiverStone and claimed $243,882.40 in unpaid contributions for the new hires; RiverStone sued for a declaratory judgment that it owed no obligation to contribute for employees hired after contract expiration.
- An NLRB administrative law judge found RiverStone committed multiple NLRA unfair labor practices during the dispute.
- The district court granted summary judgment to RiverStone, holding no contractual duty to pay post-expiration contributions and that any noncontractual claims (status‑quo duty under NLRA §8(a)(5)) fall within the NLRB’s exclusive jurisdiction.
- The Seventh Circuit affirmed, concluding federal courts may not resolve postcontract contribution disputes that rest on NLRA duties absent a contractual predicate.
Issues
| Issue | Plaintiff's Argument (RiverStone) | Defendant's Argument (Funds) | Held |
|---|---|---|---|
| Whether LMRA §301 gives federal-court jurisdiction to decide post-expiration contribution obligations | §301 permits declaratory relief to determine rights under the (expired) collective-bargaining framework | No contract obligation exists; the dispute is really about NLRA status‑quo duties and belongs to NLRB | No §301 jurisdiction to create or enforce a noncontractual post-expiration duty; NLRB has exclusive authority |
| Whether ERISA §§502/515 permit district-court enforcement of postcontract contributions | Funds can enforce contributions under ERISA against employer | Advanced Lightweight Concrete forecloses using ERISA to decide NLRA-based postcontract claims | ERISA does not confer district-court jurisdiction to adjudicate alleged NLRA violations concerning postcontract contributions |
| Whether courts may fashion federal common-law obligations under §301 (judicial inventiveness) to require contributions for new hires after expiration | Courts may develop remedies under §301 (per Lincoln Mills) to preserve status quo and effectuate LMRA policy | No statutory gap exists; NLRA §8(a)(5) and NLRB jurisdiction govern status‑quo disputes | Courts may not use §301 to create obligations that intrude on NLRB’s exclusive NLRA domain |
Key Cases Cited
- Laborers Health & Welfare Trust Fund for N. Cal. v. Advanced Lightweight Concrete Co., 484 U.S. 539 (ERISA does not authorize district courts to decide postcontract contribution disputes that implicate NLRA duties)
- NLRB v. Katz, 369 U.S. 736 (employer must maintain status quo after contract expiration; unilateral changes can violate §8(a)(5))
- Kaiser Steel Corp. v. Mullins, 455 U.S. 72 (courts must defer to NLRB on matters arguably under NLRA; §301 limited to contract disputes)
- Textile Workers Union v. Lincoln Mills of Ala., 353 U.S. 448 (courts may fashion federal remedies to enforce labor contracts, but within limits)
- William E. Arnold Co. v. Carpenters Dist. Council, 417 U.S. 12 (explains interplay between NLRA §8 and LMRA §301 jurisdiction)
- Teamsters Nat'l Auto. Transporters Indus. Negotiating Comm. v. Troha, 328 F.3d 325 (7th Cir.) (limited instances where §301 supports federal remedies necessary to effectuate collective-bargaining agreements)