Laborers Health & Welfare Trust Fund v. Advanced Lightweight Concrete Co.
Headline: Court limits federal pension-collection remedy to contractual promises, blocking trustees from suing over post-contract contribution stops and leaving bargaining disputes to labor-law agencies, affecting employers and pension funds.
Holding: The Court held that ERISA’s §515 remedy covers only contributions owed under an express plan or collective-bargaining agreement, not statutory postcontract duties under the NLRA, so trustees cannot use §515 to collect post-expiration contributions.
- Stops trustees from using ERISA §515 to collect post-contract pension contributions based on labor-law duties.
- Leaves disputes about post-expiration bargaining duties to the NLRB's labor-law process.
- Preserves ERISA’s stronger collection remedies for contractual delinquencies during an active agreement.
Summary
Background
A construction company that had been part of an industry association signed two collective-bargaining agreements requiring monthly pension contributions to eight union trust funds. The agreements expired on June 15, 1983. The company ended the association’s bargaining authority, paid through the expiration date, then stopped contributing. The trustees sued in federal court under ERISA §§ 515 and 502(g)(2) to collect contributions for the post‑expiration period, alleging the company violated its labor-law duty to maintain the status quo while new contract talks continued.
Reasoning
The Court asked whether the federal ERISA collection remedy reaches obligations created by the National Labor Relations Act as well as contractual promises. After examining the statute and legislative history, the Court concluded §515 speaks to contributions “under the terms of the plan or under the terms of a collectively bargained agreement,” and that Congress meant the ERISA remedy to enforce promised, contractual payments. The Court rejected policy arguments for a broader reading, noting that disputes over bargaining impasse and unfair labor practices are complex and are ordinarily decided by the National Labor Relations Board, not by federal courts in ERISA collection suits.
Real world impact
Because of this ruling, pension trustees cannot use ERISA §515’s powerful federal collection remedies to recover contributions that arise only from post‑contract labor-law duties; those disputes belong to the NLRB and the labor-law process. Trustees retain ERISA’s remedies for clear contractual delinquencies that arise during the term of a collective-bargaining agreement.
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