New England Carpenters Central v. Labonte Drywall Co., Inc., No. 14-1739 (1st Cir. 2015)
Annotate this CaseLabonte Drywall Company signed a statewide agreement with Union, which allowed Labonte Drywall to hire Union carpenters for its business. The agreement required Labonte Drywall to allow an audit of its records. After Labonte Drywall did not respond to certain audit requests, Plaintiffs, the trustees for a group of Union-related benefits funds and their collection agency, filed this action against Labonte Drywall under ERISA and the Labor Management Relations Act, seeking enforcement of the agreement. After a bench trial, the district court found that Labonte Drywall had terminated the agreement, and therefore, Plaintiffs had no legal right to conduct the requested audit. The First Circuit affirmed, holding (1) the district court did not clearly err in finding that the Union had actual notice of Labonte Drywall’s letter terminating its obligations under the agreement; and (2) Labonte Drywall had no duty to submit to Plaintiffs’ audit requests.
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