Trustees of Sheet Metal Workers Local 7 v. Pro Services, Inc.
65 F.4th 841
6th Cir.2023Background
- Trustees of three multiemployer fringe-benefit Funds sued Pro Services, Inc. under ERISA and the LMRA to recover unpaid contributions allegedly due for hours worked by Pro Services’ Full‑Service Maintenance Technicians (FMTs).
- The CBA at issue is the SMACNA/Local 7 agreement; it contains a caption referencing the "Construction Industry" but its Article I (Trade Jurisdiction) lists covered sheet‑metal activities including manufacture, fabrication, installation, repair, and work encompassed by the SMART Constitution (which includes factories and manufacturing plants).
- Pro Services conceded FMTs worked in manufacturing and argued the caption limits CBA coverage to construction work, so no contributions were owed for manufacturing hours; it also challenged the audit methodology for assuming all FMT hours were covered.
- The district court granted summary judgment for Pro Services, relying on the CBA caption to limit coverage to the construction industry and concluding incidental shop/manufacturing work was not "construction."
- The Sixth Circuit reversed, holding the Agreement’s substantive Trade Jurisdiction is unambiguous and covers sheet‑metal work regardless of industry; titles/headings cannot override clear contractual text. The case was remanded to determine what hours (if any) the FMTs actually performed covered work.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the CBA is limited to the construction industry by its caption | Caption is not controlling; Article I covers sheet‑metal work across industries | Caption "Construction Industry" limits CBA to construction workers | Court: Article I is unambiguous and governs; caption cannot limit clear text |
| Role of titles/headings in contract interpretation | Titles may resolve ambiguity but cannot override clear terms | Caption controls coverage even if text refers to manufacturing/shop work | Court: Follow Trainmen canon — headings only to resolve ambiguity; none here |
| Whether summary judgment was appropriate given factual disputes about FMT work | Some FMT testimony shows they performed covered sheet‑metal work; factual dispute as to hours | Audit assumed every hour was covered; Pro Services argues many hours were noncovered manufacturing work | Court: Genuine dispute of material fact exists about how much covered work occurred; summary judgment inappropriate; remand for factfinding |
Key Cases Cited
- Brotherhood of Railroad Trainmen v. Baltimore & Ohio R.R., 331 U.S. 519 (1947) (headings/titles are tools to resolve ambiguity and cannot override clear text)
- M & G Polymers USA, LLC v. Tackett, 574 U.S. 427 (2015) (apply ordinary contract principles to CBAs where consistent with federal labor policy)
- Heimeshoff v. Hartford Life & Acc. Ins. Co., 571 U.S. 99 (2013) (contractual provisions ordinarily enforced as written)
- Orrand v. Scassa Asphalt, Inc., 794 F.3d 556 (6th Cir. 2015) (summary‑judgment and ERISA plan writing principles)
- Int’l Multifoods Corp. v. Commercial Union Ins. Co., 309 F.3d 76 (2d Cir. 2002) (consider contract as a whole, including headings, when substantive provisions are ambiguous)
- Trs. of B.A.C. Loc. 32 Ins. Fund v. Fantin Enters., Inc., 163 F.3d 965 (6th Cir. 1998) (coverage defined by nature of work, not union status)
- United States v. Cain, 583 F.3d 408 (6th Cir. 2009) (consider titles only after finding ambiguity)