Local No. 496 v. Wal-Mart Real Estate Bus. Trust

CourtSuperior Court of Maine
DecidedOctober 4, 2004
DocketPENre-03-14
StatusUnpublished

This text of Local No. 496 v. Wal-Mart Real Estate Bus. Trust (Local No. 496 v. Wal-Mart Real Estate Bus. Trust) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Local No. 496 v. Wal-Mart Real Estate Bus. Trust, (Me. Super. Ct. 2004).

Opinion

STATE OF MAINE SUPERIOR COURT PENOBSCOT, ss CIVIL ACTION DOCKET # RE ‘03- 14

AMA

LOCAL NO. 496 OF THE Kt 4 Le 0% INTERNATIONAL ASSOCIATION

OF BRIDGE STRUCTURAL

ORNAMENTAL AND REINFORCING

IRONWORKERS (“Local No. 496”),

Plaintiffs Vv.

WAL-MART REAL ESTATE

) ) ) ) ) ) ) ) DECISION AND )

BUSINESS TRUST, ) ) ) ) ) ) ) ) ) ) )

ORDER

and ALVIN J. COLEMAN & SON INC., and

INDUSTRIAL ENTERPRISES INC.,

Defendants

This matter is before the Court on the two of the three Defendants’, Wal-Mart Business Trust (herein “Wal-Mart’’) and Alvin J. Coleman & Son Inc. (herein “Coleman’”), Motion for Partial Summary Judgment pursuant to Rule 56 of the Maine Rules of Civil Procedure. They are requesting this Court to enter summary judgment for the Defendants on the Plaintiff’s Complaint to the extent that Plaintiff, Ironworkers Local #496 (herein “Ironworkers’’), seeks to enforce the third Defendant’s, Industrial Enterprises Inc. (herein “Industrial”), obligations to make contributions to the Ironworkers District Council of New England Welfare, Pension and Education Fund (herein “Benefit Fund’’).

The fronworkers have also filed a Motion for Summary Judgment pursuant to Rule 56 of

the Maine Rules of Civil Procedure against the Defendants requesting this Court to enter summary judgment in their favor and order the release of Coleman’s bond in the amount of

$47,129.27, plus costs, attorney’s fees and interest from the date of the notice of the lien.

Background

In July, 2002, the Ironworkers and Industrial contracted to, among other things, construct a Wal-Mart in Brewer, Maine. Ironworker’s Statement of Material Facts ISMF)91, 3. The contract established an hourly pay rate’ under which the Ironworkers were to be paid and amounts that Industrial was to contribute to the Ironworker’s Benefit Fund. See Defendant’s Statement of Material Facts (DSMF) 94. In September 2002, Industrial contracted with Coleman to provide subcontracting work on the Wal-Mart in Brewer. DSMF $1. Industrial failed to make various payments under the contract.” DSMF 96. Ironworkers allege that they are still owed $47,129.27, of which portion consists of funds that Industrial was required to pay the Benefit Fund. Id. No express contracts were formed between the Ironworkers and Coleman-Wal-Mart. ISMEF 97. The Ironworkers’ claims against Coleman and Wal-Mart are based on Maine’s mechanic’s lien statute and not the contract with Industrial. Defendant’s Opposing Statement of Material Fact (DOSMF) §11. The Ironworkers filed a mechanic’s lien on December 20, 2002 and an amended lien on March 17, 2003. The lien was discharged at the Cumberland County Registry of Deeds and Coleman posted a bond in the amount of $47,129.27. ISMF $10.

Coleman and Wal-Mart claim that Industrial issued lien waiver certificates asserting that all of Industrial’s employees had been paid the previous week. See DSMF 95. The Ironworkers dispute having any knowledge of these waivers, ever signing the waivers and contend that any

such waivers were improper. See POSMF 95. The actual value of the work done including any

1 . Industrial agreed to pay the employees $26.50 per hour, $17 50 represented wages wi i 2 » $17 \ 28 WI amount allocated to the Benefit Fund. p ° th he remainder representing

2 In total, the Ironworkers allege that they provided 5,500 hours of labor that amounted to $150, 198.07 that Industrial originally owed to the Ironworkers. Ironworkers allege that they are still owed $47,129.27 appropriate deductions to be taken is at issue. The Ironworker’s claim that the value is based on the contract price with Industrial. See ISMF§2. Coleman and Wal-Mart claim that any amounts due to the Ironworker’s are based on the value of the work done minus deductions for cost.? See DOSMF §2. As a result, the Ironworker’s dispute all of Coleman and Wal-Mart’s alleged deductions. See DOSMF §2 and PRSF 92, DOSMF 9914-22, PRSMF 914-22. It also disputed as to when the Ironworkers actually completed their work and if the mechanic’s lien was timely filed. DOSMF 98. Discussion

A. Standard of Review

Both sides have filed motions for summary judgment. A party is entitled to summary judgment when the record shows that there is no genuine issue of material fact and the party is

entitled to judgment as a matter of law. MLR. Civ. P. 56(c); see also Darlings v. Ford Motor Co.,

2003 ME 21, $14 817 A.2d 877, 879. Essentially the Court determines whether there is a genuine issue of material fact by comparing the parties’ statement of material facts and

corresponding record references. Corey v. Norman, Hanson & DeTroy, 1999 ME 196, 98, 742

A.2d 933, 938. The Court will view the evidence in light most favorable to the non-moving

party. See Steeves v. Bernstein, Shur, Sawyer & Nelson, P.A., 1998 ME 210, P11, 718 A.2d

186.

> Coleman and Wal-Mart allege that a large number of deficiencies in the Ironworker’s construction of the Wal-Mart led to costs that must be deducted from the amount owed to the Ironworkers. Included are approximately $45,000 in added heating costs, $24,000 for Coleman to maintain heat and tenting operations, $5000 for tent materials, $4,200 in renting a telescopic lift to put tenting in pace, $2,716 to replace steel damaged by the Ironworkers with a forklift, $800 on an independent contractor, $5118 to hire an outside company to complete steel erection, $2000 in added drywall costs due to repairing the Ironworker’s work, $700 to hire a forklift operator after the Ironworkers failed to provide a qualified operator and $45,000 to hire a new project manager. B. Coleman and Wal-Mart’s Motion for Partial Summary Judgment

Coleman and Wal-Mart have filed a motion for Partial Summary Judgment alleging that Maine’s mechanic’s lien foreclosure statute is preempted in this case so far the Ironworker’s seek to enforce Industrial’s obligation to fund the Benefit Plan.

The Ironworkers brought this claim under Maine’s mechanic’s lien statute. 10 M.R.S.A. §§3251 (Supp. 2003)*. Coleman and Wal-Mart argue that Maine’s lien law relates to an ERISA benefit plan and is, therefore, preempted by ERISA. This Court finds that Maine’s lien law does not make “reference” to an ERISA benefit plan and it does not have a “connection” with a benefit plan. Pre-emption is not triggered.

1. Maine’s mechanic’s lien statute does not make “reference” to an employee

benefit plan under ERISA. Courts should presume that Congress does not intend to supplant state law. See

Maryland vy. Louisiana, 451 U.S. 725 (1981). However, the Employee Retirement Income

Security Act supercedes “any and all State laws insofar as they may . . . relate to any employee benefit plan [covered by ERISA].” 29 U.S.C. § 1144 (2004) (emphasis added). ERISA will apply to a benefit plan if it is “established or maintained by an employer engaged in commerce in any industry affecting commerce;....” 29 U.S.C. § 1003(a)(1). The word "relate" can be ambiguous, but the Court has provided guidance in two recent key decisions laying out a two-

prong test: California Div. Of labor Standards Enforcement v. Dillingham Constr,, 519 U.S. 316

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Bluebook (online)
Local No. 496 v. Wal-Mart Real Estate Bus. Trust, Counsel Stack Legal Research, https://law.counselstack.com/opinion/local-no-496-v-wal-mart-real-estate-bus-trust-mesuperct-2004.