Cons. Laborers Welfare Fund v. RoadSafe Traffic Systems, Inc., No. 22-1050 (8th Cir. 2022)
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A collective bargaining agreement (“CBA”) required RoadSafe Traffic Systems, Inc. to contribute to four employee benefits Funds. The Funds sued for unpaid contributions, alleging that the CBA unambiguously requires contributions for all hours worked by covered employees, regardless of the type of work performed. RoadSafe countered that the CBA unambiguously requires contributions only for construction and highway work. The district court granted summary judgment to RoadSafe. The issue on appeal was whether the CBA obligates RoadSafe to make contributions to the Funds for all or only specified types of work
The Eighth Circuit affirmed. The court explained that by its plain language, Article V of the CBA limits RoadSafe’s contribution obligations to “Building Construction” and “Highway/Heavy” categories of work. Because work coded as NON or “shop hours” is not within the definitions of either “Building Construction” or “Highway/Heavy,” the CBA does not require RoadSafe to make contributions for the coded work. Therefore, the district court properly granted summary judgment to RoadSafe.
Court Description: [Benton, Author, with Loken and Kobes, Circuit Judges] Civil case - Labor law. The district court did not err in interpreting the parties' Collective Bargaining Agreement and determining that the company was only obligated to make contributions to the benefit funds for certain kinds of hours worked by its employees, and not for all hours they worked; the company's records concerning the hours were sufficient to meet its ERISA obligations; an argument not presented to the district court would not be considered on appeal.
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