Twin City Pipe Trades Service Assoc. v. Wenner Quality Services, Inc., No. 16-1791 (8th Cir. 2017)
Annotate this CaseTwin City filed suit seeking to recover unpaid fringe-benefit contributions allegedly due under a collective bargaining agreement (CBA). The district court granted summary judgment for the Association on the ground that WQS was precluded by a previous lawsuit from disputing liability for the contributions as an alter ego of a signatory of the agreement. The Eighth Circuit affirmed the district court's determination that WQS was liable for the unpaid fringe-benefit contributions where all of the elements required to apply issue preclusion were present. The court held that the Association has a right to collect contributions under the CBA, but that two categories of damages were not authorized by the Employee Retirement and Income Security Act, 29 U.S.C. 1132, 1145, and that the award should be reduced accordingly. The court also upheld the district court's grant of injunctive relief. The court remanded for the district court to exclude contributions due to the Working Fee and Industry Fund from the damages award, and to reduce the award of interest accordingly.
Court Description: Colloton, Author, with Smith, Chief Judge, and Kelly, Circuit Judge] Civil case - ERISA. The district court's orders regarding an alter ego determination in prior litigation between the union and a party with which WQS was in privity constituted a valid and final judgment for purposes of issue preclusion; even though the issue of damages had been left unresolved in the prior case, there was no reason to believe the court's judgment on liability for contributions was tentative or likely to be changed; where the inability of the party to appeal was the result of their decision to file bankruptcy, the absence of appellate review of the liability decision did not require the district court to allow relitigation of the alter ego determination; the district court's determination that defendant is liable for unpaid fringe-benefit contributions is affirmed; plaintiff had standing to sue to collect contributions and recover the payments; the district court did err, however, if awarding certain damages - contributions to the Working Fee and Industry Fund - which did not arise under an ERISA plan; no error in granting plaintiff a permanent injunction to require defendant to fulfill its ongoing obligations under the Collective Bargaining Agreement.
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