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