Findlay Truck Line, Inc. v. Cen. States SE & SW Areas Pension Fund

Findlay sought relief from a withdrawal liability payment it allegedly owed the pension fund under the Multiemployer Pension Plan Amendments Act of 1980, 29 U.S.C. 1381-1461. Findlay had ceased making contributions to a pension plan administered by the fund as the result of a labor dispute. About three months after the strike began, the fund demanded Findlay pay withdrawal liability of more than $10 million. Findlay contended that withdrawal liability was improper because withdrawal occurred as the result of a labor dispute; that despite the Act’s arbitration requirement, it should not be forced to arbitrate the dispute because the withdrawal was “union-mandated;” and that despite the Act’s interim payment requirement, it should not be forced to make interim payments because doing so would cause it to suffer irreparable harm. The district court dismissed, holding that the Act required the dispute be arbitrated, and enjoined the fund from collecting withdrawal liability payments pending arbitration. The Sixth Circuit affirmed the dismissal, but reversed the injunction, stating that creating an exception to interim payments for employers that would suffer irreparable harm would contradict the congressional purpose of protecting funds from undercapitalized or financially precarious employers. View "Findlay Truck Line, Inc. v. Cen. States SE & SW Areas Pension Fund" on Justia Law