Pio v. Ross B. Hammond Co.

576 P.2d 341, 281 Or. 517, 1978 Ore. LEXIS 779, 98 L.R.R.M. (BNA) 2220
CourtOregon Supreme Court
DecidedMarch 7, 1978
DocketTC 408-020, SC 25050
StatusPublished
Cited by1 cases

This text of 576 P.2d 341 (Pio v. Ross B. Hammond Co.) is published on Counsel Stack Legal Research, covering Oregon Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pio v. Ross B. Hammond Co., 576 P.2d 341, 281 Or. 517, 1978 Ore. LEXIS 779, 98 L.R.R.M. (BNA) 2220 (Or. 1978).

Opinion

LINDE, J.

Defendant, a general construction contractor, is a party to a master labor agreement negotiated between councils of the United Brotherhood of Carpenters and Joiners of America and several associations of general contractors in Oregon and Southwest Washington. The master agreement contains a clause governing the subcontracting of work covered by the agreement to subcontractors who are not themselves signatories to the agreement. It provides that a general contractor either must require such a subcontractor to bind himself to the terms of the master agreement or the contractor must assume responsibility for payment of these employees’ wages and fringe benefits under the agreement.1 The validity of this subcontracting clause was challenged in Schlecht v. Walsh, 273 Or 221, 540 P2d 1011 (1975), upon a claim that it required a contractor to make payments to union trust funds for the benefit of others than his own employees, contrary to 29 USC § 186. This court’s construction of the master agreement was sustained by the United States Supreme Court in Walsh v. Schlecht, 429 US 401 (1977). The Court held that the payments into union trust funds required by the agreement were not for the benefit of the nonsignatory subcontractor’s employees but solely for the benefit of the employees of signatory [520]*520employers, and that they were therefore authorized by 29 USC § 186(c) (5) and (6).

In the present suit for an accounting, brought by plaintiff as assignee for trustees of the several union trust funds involved, the same subcontracting clause faces a different challenge. Defendant resists payments required by the clause with respect to work done by the employees of nonsignatory subcontractors on the ground that this requirement, coupled with the subcontractors’ obligation on projects covered by the Davis-Bacon Act2 to pay equivalent sums to their own employees, adds up to a "double payment” of the fringe benefits that prevents the economic use of nonsignatory subcontractors on such projects and therefore contravenes sections 1 and 2 of the Sherman Act.3 The trial court sustained plaintiff’s demurrer to this affirmative defense, and defendant appeals.

The antitrust defense to this labor agreement raises the issue how the subcontracting clause fares under the policies stated in Connell Construction Co. v. Plumbers Local 100, 421 US 616 (1975), the United States Supreme Court’s latest pronouncement on the relationship between the federal antitrust and labor laws. That relationship has long, and unavoidably, been a difficult one, because the labor laws represent a national policy to permit workers to organize and contract against cost competition in labor standards, while the antitrust laws forbid actions designed to restrict competitive access to any relevant market for [521]*521goods or services.4 Beyond this, the National Labor Relations Act (NLRA) itself denies unions certain indirect or "secondary” methods of gaining their objectives from one employer by pressures upon another enterprise. NLRA §§ 8(b) (4) and 8(e); 29 USC § 158(b) (4) and (e) (1970). In section 8(e), however, which makes it an unfair labor practice for a union and any employer to agree that the employer will not deal with another person or handle another employer’s products, Congress provided a special exemption for agreements concerning the subcontracting of work at a construction site.5 The interrelation of this construction industry proviso and the antitrust law was before the Court in Connell and also concerns us here.

In Connell a local union, by picketing a general contractor who normally subcontracted work by competitive bidding, obtained the contractor’s agreement to subcontract work only to firms that had a current contract with the union. The union did not represent or seek to represent the general contractor’s own employees. Of course the intended and actual effect of the agreement was to exclude all subcontractors who did not have contracts with the local union (though perhaps with other unions) from Connell’s construction projects. The Supreme Court found the anticom[522]*522petitive effect of the agreement enhanced by two factors. One was that a multiemployer contract between the union and the local mechanical contractors’ association contained a so-called "most favored nation” clause which guaranteed each contracting employer the benefit of any union concession to any other employer, and which would "eliminate competition on all subjects covered by the multiemployer agreement, even on subjects unrelated to wages, hours, and working conditions,” though the Court did not state what these subjects might be. The second factor was that the subcontracting clause obtained from general contractors like Connell gave the union complete control over access to the market for such subcontracting work by refusing to sign agreements with new or "outside” employers. 421 US at 623-624. The Court concluded that the control thus created by agreement with the general contractors allowed a "direct restraint on the business market.. . that would not follow naturally from the elimination of competition over wages and working conditions,” analogous to the closed market that was held to violate the Sherman Act in Allen Bradley Co. v. Local 3, IBEW, 325 US 797 (1945). 421 US at 625. Finally, the Court held that the clause restricting subcontract work to employers organized by the local union was not a legitimate organizing device privileged by the construction industry proviso of section 8(e), supra note 5. 421 US at 626-633.

Defendant in the present case contends that the subcontracting clause in the master labor agreement, by requiring "double payment” of fringe benefits when a nonunion subcontractor is used on a construction project covered by the Davis-Bacon Act, has the same effect of excluding nonunion subcontractors as the express provision that was condemned in Connell. Plaintiff, on the other hand, contends that the subcontracting clause in this case is privileged under section 8(e) because, unlike that in Connell, it is part of a [523]*523collective bargaining agreement with the prime contractor.

If the decision depends merely on matching facts, this case is easy to distinguish from Connell. However, surface similarities or differences between the cases do not necessarily correspond to the divergent elements of congressional policy that Connell and its predecessors seek to accommodate.

It is not clear, for instance, that the subcontracting clause is immune from attack merely because this union is the collective bargaining agent for the general contractor’s employees. On that issue, plaintiff urges upon us a paragraph from Connell as if that opinion had placed it "beyond argument” that the clause would be exempt from antitrust law if it were a part of a collective bargaining agreement. The paragraph actually states:

There can be no argument in this case, whatever its force in other contexts, that a restraint of this magnitude might be entitled to an antitrust exemption if it were included in a lawful collective-bargaining agreement. Cf. Mine Workers v. Pennington, 381 U. S., at 664-665; Jewel Tea, 381 U. S., at 689-690 (opinion of White, J.); id., at 709-713, 732-733 (opinion of Goldberg, J.). In this case, Local 100 had no interest in representing Connell’s employees.

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Cite This Page — Counsel Stack

Bluebook (online)
576 P.2d 341, 281 Or. 517, 1978 Ore. LEXIS 779, 98 L.R.R.M. (BNA) 2220, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pio-v-ross-b-hammond-co-or-1978.