Nesse v. Green Nature-Cycle, LLC, No. 20-2365 (8th Cir. 2021)
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Trustees of five multi-employer benefits funds filed suit against Green Nature under section 515 of the Employee Retirement Income Security Act (ERISA) and section 301 of the Labor Management Relations Act (LMRA), alleging that Green Nature failed to contribute to the funds on behalf of its non-union employees and sought to collect from Green Nature the delinquent contributions, interest, costs, and attorney's fees.
The Eighth Circuit affirmed the district court's grant of summary judgment in favor of the trustees. The court concluded that the district court correctly determined that the collective bargaining agreement (CBA) unambiguously required fringe benefit contributions for non-union employees. The court also found that an award of delinquent fringe benefit contributions would not improperly require Green Nature to "duplicate fringe contributions." The court need not determine whether issue preclusion could ever be a valid defense to a collection action because the substantive elements of issue preclusion are not satisfied. Finally, the district court did not abuse its discretion in awarding the trustees attorney's fees and in declining to reduce the amount.
Court Description: [Shepherd, Author, with Smith, Chief Judge, and Grasz, Circuit Judge] Civil case - ERISA and Labor Management Relations Act. The Collective Bargaining Agreement at issue in the case unambiguously required Green Nature to make fringe benefit contributions on behalf of non-union employees; direct payment of fringe benefits to the non-union employees as a result of a state audit did not relieve Green Nature of its obligation to pay the benefits to the union welfare funds; the state audit did not collaterally estop the welfare fund from seeking the delinquent contributions; the district court did not err in awarding the trustees attorneys' fees or in declining to reduce the amount sought.
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