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Trustees of the National Automatic Sprinkler Industry Welfare Fund v. IT&M Division, Inc.
8:12-cv-03434
D. Maryland
Aug 4, 2014
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Background

  • Plaintiffs are ERISA employee benefit funds seeking delinquent contributions, interest, liquidated damages, and fees from IT&M Division, Inc.
  • IT&M executed Assent/Interim Agreements binding it to the Local 669 CBA and NASI Funds Trust Agreements, requiring monthly contributions and reports.
  • Audit by Salter & Company covering January 2009–June 30, 2012 underpinning many claims; IT&M challenged certain computations.
  • Funds claim additional unpaid contributions for various periods (Nov 2010–Jul 2011; Jan 2009–Jun 2012; Jul 2012–Mar 2013) and corresponding interest and liquidated damages.
  • IT&M contends calculations are inaccurate, disputes hours and rates, and argues some periods are duplicative of prior judgments; Funds moved for summary judgment and damages calculations were supplemented.
  • Court granted summary judgment on liability and damages in total amounts requested, with a separate Order to issue on costs and fees.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether Funds are entitled to summary judgment on liability for unpaid contributions. NASI Funds rely on audit findings showing unpaid contributions. IT&M disputes audit figures and hours worked, seeks reduction/duplication defenses. Yes; summary judgment granted on liability based on audit results.
Whether the damages calculations (interest and liquidated damages) are supported by the record. Funds provided calculations for interest and liquidated damages tied to each period. IT&M challenges specific calculations and potential duplications. Yes; damages awarded as claimed for all periods after consideration.
Whether post-termination period (after June 2012) contributions remained due through March 31, 2013. CBA and Guidelines bound IT&M until March 31, 2013. Termination ended accrual of benefits but not contributions; IT&M argues no further contributions due. Yes; IT&M liable through March 31, 2013.
Whether prior judgments or duplicative claims affect current damages. No reduction for duplicative periods shown in record. Certain months' amounts may duplicate earlier judgments. Court found no improper duplication; damages maintained.

Key Cases Cited

  • Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (Supreme Court (1986)) (establishes standard for summary judgment evidence and genuine disputes of material fact)
  • Celotex Corp. v. Catrett, 477 U.S. 317 (Supreme Court (1986)) (sets forth burden on movant to show absence of genuine issue)
  • Bouchat v. Baltimore Ravens Football Club, Inc., 346 F.3d 514 (4th Cir. 2003) (permits summary judgment when no genuine factual dispute)
  • Dulaney Packaging Corp. v. ???, 673 F.3d 323 (4th Cir. 2012) (applies standard for evaluating audit-based liability without specific audit errors)
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Case Details

Case Name: Trustees of the National Automatic Sprinkler Industry Welfare Fund v. IT&M Division, Inc.
Court Name: District Court, D. Maryland
Date Published: Aug 4, 2014
Docket Number: 8:12-cv-03434
Court Abbreviation: D. Maryland