Federal Contract Guards of America v. Ohio Security Systems, Inc.

CourtDistrict Court, E.D. New York
DecidedFebruary 20, 2025
Docket2:24-cv-00548
StatusUnknown

This text of Federal Contract Guards of America v. Ohio Security Systems, Inc. (Federal Contract Guards of America v. Ohio Security Systems, Inc.) is published on Counsel Stack Legal Research, covering District Court, E.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Federal Contract Guards of America v. Ohio Security Systems, Inc., (E.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK --------------------------------------------------------------X FEDERAL CONTRACT GUARDS OF AMERICA,

Plaintiff, REPORT AND RECOMMENDATION

-against- 24-cv-548-DLI-ST

OHIO SECURITY SYSTEMS, INC.,

Defendant. --------------------------------------------------------------X TISCIONE, United States Magistrate Judge:

Federal Contract Guards of America (“Plaintiff”) sued Ohio Security Systems, Inc. (“Defendant” and together with Plaintiff, the “Parties”) to confirm an arbitration award issued in Plaintiff’s favor. Before the Court is Plaintiff’s Second Motion for Default Judgment (the “Motion”) against Defendant. For the reasons discussed below, this Court respectfully recommends that the District Court GRANT the Motion and confirm the arbitration award. However, this Court respectfully recommends that the District Court DENY Plaintiff’s requests for attorney and process server fees for failure to submit sufficient documentation in support of those requests. BACKGROUND Plaintiff, a labor union representing security guards, and Defendant, a security guard services provider, have been parties to a series of collective bargaining agreements (“CBAs”)1 since 2018. See Compl. ¶¶ 4–6, ECF No. 1. The CBAs provide a multi-step employee grievance procedure and dispute resolution process, which culminates in arbitration. Id. ¶ 7; Arbitration

1 The applicable CBAs cover the periods of 2018-2020, 2021, and 2022-2025. See Wien Aff. Ex. A. at 2 n.1, ECF No. 12-2 (hereinafter the “Arbitration Award”). Award at 3 (citing CBAs Art. 7). The CBAs specifically provide that an arbitrator “shall conduct a hearing on the grievance” and that the “decision or order of an Arbitrator shall be final and binding and shall be in writing.” Arbitration Award at 3 (citing CBAs § 7.2). Over the course of the Parties’ contractual relationship, Defendant violated the CBAs in various ways. See Compl. ¶ 8. For example, Defendant failed to pay its employees as required,

including holiday, vacation, and sick leave pay, as well as wage increases. Id. Defendant also terminated one employee without cause and failed to comply with the CBAs’ health and safety provisions. Id. These grievances were memorialized and went through the CBAs’ proscribed grievance procedure. Id. ¶ 9. Ultimately, after exhaustion of the grievance procedure’s lower steps, Plaintiff advanced these grievances to arbitration. Id. On December 12, 2023, Plaintiff presented evidence regarding these grievances at an arbitration hearing before an assigned arbitrator, J.J. Pierson (“Arbitrator Pierson”). Id. ¶¶ 9, 11. Although both Arbitrator Pierson and Plaintiff notified Defendant of the arbitration hearing, Defendant failed to appear at the hearing, or otherwise respond to the allegations that Plaintiff

presented at the hearing. Id. Upon the hearing’s conclusion, Arbitrator Pierson found Plaintiff’s claims meritorious and, on December 17, 2023, issued an award in Plaintiff’s favor.2 Id. ¶ 12. The Arbitration Award awarded Defendant’s aggrieved employees backpay to be paid within fourteen days. Id. ¶¶ 12, 13; Arbitration Award at 5–11. The Arbitration Award also ordered Defendant to comply with future obligations under the CBAs, submit an audit of its payroll records, reinstate the employee it had terminated without cause, and reimburse Plaintiff for half of Arbitrator Pierson’s fees (and, if

2 Plaintiff incorrectly claims that it attached the Arbitration Award to the Complaint. See Compl. ¶ 12. Plaintiff only attached the Arbitration Award to its counsel’s affidavit in support of the Motion. Plaintiff had to enforce the Arbitration Award through court action, the filing fee). Id. ¶ 14; Arbitration Award at 11–12. The Arbitration Award was served on Defendant. Compl. ¶ 15. However, Defendant never made the required backpay or otherwise complied with the Arbitration Award. Id. ¶¶ 13, 16. Resultingly, on January 25, 2024, Plaintiff commenced this action under Section 301 the Labor

Management Relations Act (“LMRA”) to confirm the Arbitration Award. Id. ¶ 1; see 29 U.S.C. § 185(a) (“Suits for violation of contracts between an employer and a labor organization . . . may be brought in any district court of the United States having jurisdiction of the parties . . . .”). Defendant failed to move to vacate the Arbitration Award or otherwise appear in the action. Compl. ¶ 17. Plaintiff therefore requested a certificate of default, which the Clerk of Court entered against Defendant on April 18, 2024. See Entry of Default, ECF No. 9. Plaintiff moved for default judgment against Defendant on May 13, 2024. See First Mot. Default J., ECF No. 10. However, Plaintiff’s first motion failed to comply with the Court’s individual rules, as well as the Local Civil Rules. See Docket Order Striking First Mot. for Default

J., dated May 15, 2024. Accordingly, the District Court struck the first motion as deficient but allowed Plaintiff to file a new one. See id. Plaintiff thus filed this Motion on May 16, 2024. See Mot., ECF No. 12. The Honorable Dora Lizette Irizarry referred the Motion to this Court for Report & Recommendation on July 18, 2024. See Docket Order, dated July 18, 2024. LEGAL STANDARD The Court’s review of an arbitration award under LMRA § 301 is “very limited.” Nat’l Football League Mgmt. Council v. Nat’l Football Leagues Players Ass’n, 820 F.3d 527, 536 (2d Cir. 2016) (citing Major League Baseball Players Ass’n v. Garvey, 532 U.S. 504, 509 (2001)). “This is because the Second Circuit ‘repeatedly has recognized the strong deference appropriately due arbitral awards and the arbitral process.’” Hyundai Cap. Am. v. Gooding, 24-cv-803 (DLI), 2024 WL 4132380, at *2 (E.D.N.Y. Sept. 10, 2024) (citing Porzig v. Dresdner, Kleinwort, Benson, N. Am. LLC, 497 F.3d 133, 138–39 (2d Cir. 2007)). Courts are therefore “not authorized to review the arbitrator’s decision on the merits . . . but [may] inquire only as to whether the arbitrator acted within the scope of his authority as defined by the collective bargaining agreement.” Nat’l

Football League Mgmt. Council, 820 F.3d at 536; see Int’l Brotherhood of Elec. Workers, Loc. 97 v. Niagara Mohawk Power Corp., 143 F.3d 704, 715 (2d Cir. 1998) (“It is abundantly clear that courts must tread lightly when reviewing arbitral decisions.”). It is not the Court’s “task to decide how [it] would have conducted the arbitration proceedings, or how [it] would have resolved the dispute.” Nat’t Football League Mgmt. Council, 820 F.3d at 537. The arbitrator’s award is “legitimate and enforceable as long as it draws its essence from the collective bargaining agreement and is not merely an exercise of the arbitrator’s own brand of industrial justice.” Niagara Mohawk Power Corp., 143 F.3d at 714 (citations and quotations omitted). Even if “a court believes an arbitrator to have committed serious legal or factual error,”

the court must confirm the arbitrator’s decision so long as “the arbitrator is ‘even arguably construing or applying the contract and acting within the scope of his authority.’” Id. at 715 (citing United Paperworkers Int’l Union v. Misco, Inc., 484 U.S. 29, 38 (1987)).

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Federal Contract Guards of America v. Ohio Security Systems, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/federal-contract-guards-of-america-v-ohio-security-systems-inc-nyed-2025.