Board of Trustees of the IUOE Local 4 Pension Fund v. Alongi

CourtDistrict Court, D. Massachusetts
DecidedSeptember 14, 2023
Docket1:21-cv-10163
StatusUnknown

This text of Board of Trustees of the IUOE Local 4 Pension Fund v. Alongi (Board of Trustees of the IUOE Local 4 Pension Fund v. Alongi) is published on Counsel Stack Legal Research, covering District Court, D. Massachusetts primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Board of Trustees of the IUOE Local 4 Pension Fund v. Alongi, (D. Mass. 2023).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS

_______________________________________ ) BOARD OF TRUSTEES of the IUOE ) LOCAL 4 PENSION FUND, BOARD OF ) TRUSTEES of the IUOE LOCAL 4 ) ANNUITY & SAVINGS FUND, BOARD ) OF TRUSTEES of the IUOE LOCAL 4 ) HEALTH and WELFARE FUND, BOARD ) OF TRUSTEES of the HOISTING and ) PORTABLE ENGINEERS LOCAL 4 ) Civil Action No. APPRENTICESHIP & TRAINING FUND, ) 21-cv-10163-FDS INTERNATIONAL UNION of ) OPERATING ENGINEERS LOCAL 4, ) IUOE LOCAL 4 LABOR-MANAGEMENT ) COOPERATION TRUST, and IUOE ) LOCAL 4 SOCIAL ACTION ) COMMITTEE, ) ) ) Plaintiffs, ) ) v. ) ) GINA ALONGI, ) ) Defendant. ) _______________________________________)

MEMORANDUM AND ORDER ON PLAINTIFFS’ MOTION FOR PARTIAL SUMMARY JUDGMENT

SAYLOR, C.J. This is an action arising under the Employee Retirement Income Security Act of 1974 (“ERISA”), 29 U.S.C. § 1001, et seq. Plaintiffs the Board of Trustees of the IUOE Local 4 Pension Fund; the Board of Trustees of the IUOE Local 4 Annuity & Savings Fund; the Board of Trustees of the IUOE Local 4 Health and Welfare Fund; the Board of Trustees of the Hoisting and Portable Engineers Local 4 Apprenticeship & Training Fund (collectively, the “Funds”); the International Union of Operating Engineers Local 4; the IUOE Local 4 Labor-Management Cooperation Trust; and the IUOE Local 4 Social Action Committee allege that defendant Gina Alongi breached her fiduciary duties during her employment as the Administrator for the Funds. In substance, the complaint alleges that Alongi diverted pension-plan assets for her own benefit

and the benefit of an entity unrelated to the Funds, neglected her work, and otherwise breached her duties as plan administrator. Alongi has filed several counterclaims, alleging that her supervisor sexually harassed her, that the Funds refused to accommodate her disability, and that the Funds retaliated against her for reporting the harassment. Plaintiffs have moved for partial summary judgment with respect to Alongi’s liability for breach of her fiduciary duties. While there is certainly evidence that Alongi did, in fact, exercise discretionary authority over the assets of the Funds, and directed the use of those assets in a manner contrary to law and the interests of plans and their beneficiaries, the underlying facts are sufficiently disputed that the entry of summary judgment is not warranted. Accordingly, and for the following reasons, plaintiffs’ motion for partial summary judgment will be denied.

I. Background A. Factual Background Except where otherwise noted, the following facts are undisputed. 1. Governance of the Funds Generally The Funds comprise several multiemployer employee-benefit plans, all of which are subject to the regulatory framework of ERISA. (Def.’s SMF ¶¶ 1, 3, 5, 13). Each fund is governed by a Board of Trustees, who in turn employ staff to work for the funds. (Id. ¶¶ 17, 20). The Administrator is appointed by the Boards of Trustees of the Funds and serves as the main liaison between the Funds and certain employees, professional advisers, and service providers. (Id. ¶¶ 26-30; Geiman Decl. ¶ 2). The Administrator also organizes regular meetings to provide various relevant reports to the Funds. (Def.’s SMF ¶¶ 30-31). The role is a full-time occupation. (Id. ¶ 32; Geiman Decl. ¶ 2). According to the Funds, “the Trustees expected that the Administrator would be present in the office during the normal business hours and would devote her full working hours to the operations of the Funds.” (Pls.’ Mem. at 4).1

2. Gina Alongi’s Work as Administrator Gina Alongi served as Administrator for the Funds from 1996 to July 2020. (Def.’s SMF ¶ 33; Alongi Dep. Vol. I at 27, Pls.’ App’x at 138; Alongi Dep. Vol. III at 9, Pls.’ App’x at 146). She received an annual salary averaging $242,000 during the period from 2016 to 2019. (Def.’s SMF ¶ 175; Geiman Decl. ¶ 30). She received other benefits, including employer-provided automobiles and contributions to her pension plan. (Def.’s SMF ¶ 175; Geiman Decl. ¶ 30). She was also entitled to several weeks of paid vacation, although the number of weeks is disputed. (Def.’s SMF ¶ 253; see Employee Handbook, Ex. 6, Pls.’ App’x at 70-71). Her total compensation package averaged $338,658 per year during the period 2016-2019. (Def.’s SMF ¶¶ 36, 175).

3. The Shared Services Agreement In December 2003, amended effective July 1, 2006, the Funds entered into a Shared Services Agreement. (See Shared Services Agreement, Ex. 5, Pls.’ App’x at 49). The purpose of

1 It is not clear that this expectation was an official policy of the Funds. The Funds cite to paragraphs 265 and 266 of their Concise Statement of Material Facts, but those paragraphs refer to a sexual relationship between Alongi and a member of the Board of Trustees (¶ 265) and the Health Fund Trust Agreement (¶ 266), respectively. (CSMF ¶¶ 265-66). It appears that William McLaughlin, who became Business Manager of the IUOE Local 4 Union and Chairman of the Boards of Trustees in 2017, expected employees to work in person from 8:00 a.m. to 4:00 p.m., the business hours provided by the Employee Handbook of the IUOE Local 4 Fringe Benefit Funds Office. (See McLaughlin Notes, Ex. 156, Def.’s App’x at 33; Employee Handbook, Ex. 6, Pls.’ App’x at 67 (noting that employees of the Funds are expected to “[r]eport to work regularly and on time” and providing that the “regular working hours of the Funds Office are 8:00 a.m. – 4:00 p.m.”)). the Agreement was to ensure that no fund was subsidizing the operating costs of any other fund. (Alongi Dep. Vol. III at 93, Pls.’ App’x at 153). The Shared Services Agreement provides: The amount of staff time of employees of the Fund Office devoted to each Organization will be used as the basis for determining the allocable portion of general administrative expenses, staff salary, taxes and benefits, and common overhead expenses, including but not limited to office space, utilities, professional fees and computer costs. The Fund Office Staff will maintain records of the amount of salary during each pay period charged to each Organization by each employee of the Office and the amount of time spent by Fund Office Staff who perform work for more than one Organization on the work performed for each organization. (Shared Services Agreement, Ex. 5, Pls.’ App’x at 50-51).2 Under the Agreement, those records are used to allocate charges and reimbursements between the Funds for expenses created by employees. (Shared Services Agreement, Ex. 5, Pls.’ App’x at 51-52). 4. Alongi’s Work for the Coalition From 2007 to 2021, in addition to her position as Administrator of the Funds, Alongi also served as Executive Director of the Massachusetts Coalition of Taft-Hartley Funds (“the Coalition”). (Alongi Aff. ¶ 25; Def.’s SMF ¶ 144). The Coalition is “a membership organization consisting of different union-sponsored multiemployer health and welfare plans in the New England area.” (Geiman Decl. ¶ 16; Def.’s SMF ¶ 87). One of the purposes of the Coalition is to use the combined purchasing power of its members to secure more favorable terms from healthcare providers. (Geiman Decl. ¶ 16; Def.’s SMF ¶ 88). Until December 31,

2 The Funds Office Employee Handbook also contains a recordkeeping requirement: All employees (exempt or non-exempt) that work under the jurisdiction of more than one (1) Fund must complete a weekly timesheet . . . to be turned in every Friday by 4 p.m. Timesheets are used to break down employees’ hours, (all hours, including overtime), spent on particular Funds. (Employee Handbook at 4, Ex. 6, Pls.’ App’x at 63). 2020, the Local 4 Welfare Fund was a member of the Coalition. (Geiman Decl. ¶ 18; Def.’s SMF ¶ 183).

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