Locals 302 and 612 of the International Union of Operating Engineers Construction Industry Health and Security Fund v. O'Bunco Engineering International Inc.

CourtDistrict Court, W.D. Washington
DecidedSeptember 12, 2024
Docket2:23-cv-00810
StatusUnknown

This text of Locals 302 and 612 of the International Union of Operating Engineers Construction Industry Health and Security Fund v. O'Bunco Engineering International Inc. (Locals 302 and 612 of the International Union of Operating Engineers Construction Industry Health and Security Fund v. O'Bunco Engineering International Inc.) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Locals 302 and 612 of the International Union of Operating Engineers Construction Industry Health and Security Fund v. O'Bunco Engineering International Inc., (W.D. Wash. 2024).

Opinion

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3 4 5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 LOCALS 302 AND 612 OF THE CASE NO. 2:23-cv-810 8 INTERNATIONAL UNION OF OPERATING ENGINEERS ORDER GRANTING PLAINTIFFS’ 9 CONSTRUCTION INDUSTRY MOTION FOR SUMMARY HEALTH AND SECURITY FUND, JUDGMENT 10 LOCALS 302 AND 612 OF THE INTERNATIONAL UNION OF 11 OPERATING ENGINEERS- EMPLOYERS CONSTRUCTION 12 INDUSTRY RETIREMENT FUND, and WESTERN WASHINGTON 13 OPERATING ENGINEERS- EMPLOYERS TRAINING TRUST 14 FUND,

15 Plaintiffs, 16 v. 17 O'BUNCO ENGINEERING INTERNATIONAL INC., 18 Defendant. 19

20 1. INTRODUCTION 21 This matter comes before the Court on Plaintiffs Locals 302 and 612 of the 22 International Union of Operating Engineers Construction Industry Health and 23 1 Security Fund, Locals 302 and 612 of the International Union of Operating 2 Engineers-Employers Construction Industry Retirement Fund, and Western

3 Washington Operating Engineers-Employers Training Trust Fund’s (collectively, 4 the “Trust Funds”) motion for summary judgment. Dkt. No. 13. Having considered 5 the Trust Funds’ motion, Defendant O’Bunco Engineering International Inc.’s 6 (“O’Bunco”) response, and the relevant record, as well as the argument of counsel, 7 the Court GRANTS the Trust Fund’s motion and enters judgment against O’Bunco 8 for $103,890.77.1

9 2. BACKGROUND 10 The Trust Funds are multiemployer, collectively bargained employee benefit 11 plans regulated by the Employee Retirement Income Security Act of 1974 12 (ERISA),29 U.S.C. § 1001—1461, and the Labor Management Relations Act 13 (LMRA), 29 U.S.C. § 186(c)(5). Dkt. No. 1 ¶ 1.1-1.4. Employers contribute funds on 14 behalf of their employees, and the Trust Funds provide benefits to eligible operating 15 engineers, their dependents, and beneficiaries in Western Washington. Dkt. No. 14

16 ¶ 3. A third-party administrator, Welfare and Pension Administrative Services, Inc. 17 (“WPAS”), administers the Trust Funds. Id. In this capacity, WPAS provides payroll 18 and auditing services based on the terms of the labor agreements between 19 International Union of Operating Engineers Locals 302 and 612 and each signatory 20 employer. Id. ¶ 4. 21

22 1 The Trust Funds seek $104,506.62. The Court slightly decreases the amount based 23 on its calculation of liquidated damages. See infra Section 3.3. 1 The following facts are undisputed. O’Bunco signed Letters of Assent binding 2 it to six project labor agreements for public works projects in Western Washington.

3 Dkt. Nos. 1 ¶¶ 3.2, 3.7, 3.12, 3.16, 3.21, 3.26; 8 ¶ 1. O’Bunco agreed to pay fringe 4 benefits to the Trust Funds based on each hour of covered work performed by its 5 employees on each respective project. Dkt. Nos. 1 ¶¶ 3.4, 3.5, 3.9, 3.10, 3.13, 3.14, 6 3.18, 3.19, 3.23, 3.24, 3.28, 3.29; 8 ¶ 1. 7 WPAS selected O’Bunco for an audit of its payroll and related business 8 records for the period of April 1, 2020, through September 30, 2020. Dkt. No. 14

9 ¶ 13. After receiving updated records, WPAS completed an amended audit report on 10 March 5, 2024, finding O’Bunco had both under and overpaid fringe benefit 11 contributions due to clerical errors. Dkt. Nos. 14 ¶¶ 14-15; 15 ¶ 10. The parties 12 agree O’Bunco underpaid $109,439.30 and overpaid $94,445.83 in fringe benefit 13 contributions during the audit period. Dkt. Nos. 15 ¶ 10; 16 at 4. 14 The only remaining issue in this case is how much of O’Bunco’s overpayments 15 should be applied to reduce the amount owed in underpayments. Based on the

16 testimony of Jonathan Sullivan, WPAS Data Controller, the Trust Funds state they 17 can credit $81,365.29 of the $94,445.83 overpayment to O’Bunco’s underpayment 18 without adversely affecting their employees’ healthcare eligibility and retirement 19 benefits. Dkt. No. 14 ¶ 18. O’Bunco argues to the contrary that the Trust Funds 20 should credit the full amount because Sullivan’s testimony is too speculative to 21 support withholding $13,080.54 (i.e., the difference between Sullivan’s refund

22 calculation and the total overpayment). 23 1 3. DISCUSSION 2 3.1 Standard of review. “[S]ummary judgment is appropriate when there is no genuine dispute as to 3 any material fact and the movant is entitled to judgment as a matter of law.” 4 Frlekin v. Apple, Inc., 979 F.3d 639, 643 (9th Cir. 2020) (internal citation omitted). 5 A dispute is “genuine” if “a reasonable jury could return a verdict for the nonmoving 6 party,” and a fact is material if it “might affect the outcome of the suit under the 7 governing law.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). When 8 considering a summary judgment motion, courts must view the evidence “‘in the 9 light most favorable to the non-moving party.”’ Barnes v. Chase Home Fin., LLC, 10 934 F.3d 901, 906 (9th Cir. 2019) (internal citation omitted). “[S]ummary judgment 11 should be granted where the nonmoving party fails to offer evidence from which a 12 reasonable jury could return a verdict in its favor.” Triton Energy Corp. v. Square D 13 Co., 68 F.3d 1216, 1221 (9th Cir. 1995). Summary judgment should also be granted 14 where there is a “complete failure of proof concerning an essential element of the 15 non-moving party’s case.” Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). 16 However, if a nonmoving party “shows by affidavit or declaration that, for 17 specified reasons, it cannot present facts essential to justify its opposition, the court 18 may: (1) defer considering the motion or deny it; (2) allow time to obtain affidavits 19 or declarations or to take discovery; or (3) issue any other appropriate order.” Fed. 20 R. Civ. P. 56(d). Even so, district courts may deny “further discovery if the movant 21 has failed diligently to pursue discovery in the past, . . . or if the movant fails to 22 23 1 show how the information sought would preclude summary judgment.” California 2 Union Ins. Co. v. Am. Diversified Sav. Bank, 914 F.2d 1271, 1278 (9th Cir. 1990).

3 3.2 O’Bunco fails to provide evidence refuting the only disputed point in this litigation, and thus summary judgment is appropriate. 4 The parties agree on the controlling law. ERISA § 403(c)(2)(A)(ii) permits a 5 plan to refund an employer’s mistaken contribution within six months. This section 6 operates as “an exception to the general rule prohibiting plan assets from inuring to 7 the benefit of employers.” Award Serv., Inc. v. N. California Retail Clerks Unions & 8 Food Emps. Joint Pension Tr. Fund, 763 F.2d 1066, 1070 (9th Cir. 1985). To receive 9 a refund, employers must establish two points: (1) their overpayments were made 10 based on a mistake of fact or law; and (2) the equities favor restitution. Brit. Motor 11 Car Distributors, Ltd. v. San Francisco Auto. Indus. Welfare Fund, 882 F.2d 371, 12 374 (9th Cir. 1989). 13 O’Bunco’s overpayments occurred as a result of “clerical errors” similar to 14 those that caused O’Bunco’s underpayments. Dkt. No. 15 ¶ 10.

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Locals 302 and 612 of the International Union of Operating Engineers Construction Industry Health and Security Fund v. O'Bunco Engineering International Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/locals-302-and-612-of-the-international-union-of-operating-engineers-wawd-2024.