TEAMSTERS HEALTH AND WELFARE FUND OF PHILADELPHIA AND VICINITY v. MECO TRUCKING COMPANY
1:14-cv-07886
| D.N.J. | Jun 2, 2017Background
- Plaintiffs: multi-employer Teamsters Pension and Health & Welfare Funds (and Administrator) sued Meco Trucking for alleged unpaid benefit contributions for 2006–2014 based on payroll audits. Plaintiffs seek unpaid contributions, interest, liquidated damages, and fees.
- Meco employed drivers/haulers covered by two collective bargaining agreements with Teamsters Local 384: a Material Hauling Agreement (MHA) (which contains an hours cap for contributions) and a Five-County Agreement (FCA) (which sets higher rates for on-site construction work and contains no cap).
- Dispute centers on whether hours paid under the FCA (construction-site hours) must be combined with MHA hours when applying the MHA cap (Meco’s position: combine/coalesce; Funds’ position: do not combine).
- Audits for 2006–2014 found alleged underpayments; parties stipulated facts and submitted written testimony (no live testimony). Plaintiffs filed suit December 18, 2014.
- Second major dispute: statute of limitations — six-year limitations period; plaintiffs concede 2006 is time-barred but invoke the discovery rule to preserve some pre-2009 claims; court found plaintiffs had notice earlier and barred claims prior to December 18, 2008.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether FCA hours count toward MHA cap | Cap applies only to hours under MHA; FCA hours are not included | MHA and FCA "coalesce": combine hours under both agreements to compute the MHA cap | FCA hours are not included when computing the MHA cap; cap applies only to MHA hours |
| Meaning of "work exclusively on a construction job site" in Article 30 MHA | Phrase distinguishes on-site (FCA) work from hauling (MHA); on-site hours must be paid under FCA and not subject to MHA cap | "Exclusivity" means if any part of day is on-site, MHA governs contributions or hours should be aggregated | Term is ambiguous but interpreted in context to mean FCA applies to job-site hours and those hours are not subject to the MHA cap |
| Whether plaintiffs may recover contributions before Dec. 18, 2008 (statute of limitations) | Discovery rule delayed accrual until plaintiffs completed audits and notified Meco (plaintiffs cite March 12, 2010) | Funds had notice earlier (audits and communications dating back to 1999–2007); plaintiffs failed to exercise reasonable diligence | Discovery rule does not save claims prior to Dec. 18, 2008; claims before that date are time-barred |
| Whether court should read an unexpressed term into the Agreements (i.e., combine agreements to apply cap) | N/A (plaintiffs oppose implying such a term) | Argues industry practice and prior communications justify reading in coalescing term | Court will not read unexpressed terms into the contracts; absence of express language defeats Meco's coalescing theory |
Key Cases Cited
- M&G Polymers USA, LLC v. Tackett, 135 S. Ct. 926 (2015) (CBAs interpreted under ordinary contract-law principles)
- Tessmar v. Grosner, 23 N.J. 193 (1957) (court must determine parties' intent from contract language and circumstances)
- Schor v. FMS Financial Corp., 357 N.J. Super. 185 (App. Div. 2002) (ambiguity exists only if contract is susceptible to at least two reasonable interpretations)
- County of Morris v. Fauver, 153 N.J. 80 (1998) (discovery rule generally does not apply to contract actions; plaintiffs must exercise reasonable diligence)
- Staub v. Eastman Kodak Co., 320 N.J. Super. 34 (App. Div. 1999) (describing discovery rule as delaying accrual until injury is or should be discovered)
- Celanese Ltd. v. Essex County Improvement Authority, 404 N.J. Super. 514 (App. Div. 2009) (contract interpreted in light of whole agreement and circumstances)
- Hardy ex rel. Dowdell v. Abdul-Matin, 198 N.J. 95 (2009) (contracts should be read in a common-sense manner)