Viking Freight, Inc. v. Moberg

CourtSuperior Court of Maine
DecidedJanuary 6, 2000
DocketCUMcv-97-225
StatusUnpublished

This text of Viking Freight, Inc. v. Moberg (Viking Freight, Inc. v. Moberg) 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
Viking Freight, Inc. v. Moberg, (Me. Super. Ct. 2000).

Opinion

page cte aie bbe

STATE OF ieiew..:. Gumberland, gs, Gleri’s Gfirs STATE OF MAINE SUPERIOP CO1'— SUPERIOR COURT

CUMBERLAND, ss. wd CIVIL ACTION Ji * {e,00d DOCKET NO. CV-97-225" ; , EAA ic VIKING FREIGHT, INC., R ECENVED Plaintiff, v. DECISION AND ORDER

MARK MOBERG, et al.,

Ne ee a ee ee Ne Ne Ne Se”

Defendants.

1 FACTUAL AND PROCEDURAL BACKGROUND

Plaintiff Viking Freight, Inc. once operated four terminals of a nation-wide trucking system in Maine. Stipulation, ¥1. The four terminals were located in Bangor, Portland, Presque Isle and Sidney. Stipulation, (2. Additionally, Viking operated a general corporate office in Bangor that served as headquarters for Viking’s Northeast operations. Stipulation, 193-4. In September of 1996, Viking announced the closing of the Bangor regional headquarters, which was comprised of two buildings, a general office and an annex to that building. Stipulation, 156. During 1997, Viking closed its four Maine terminals. Stipulation 11-12.

Viking commenced this action, seeking declaratory judgment to determine its liability under Maine’s Severance Pay Statute, 26 M.R.S.A. §625-B. Intervening Defendants (“Defendants”) counterclaimed under the federal Worker Adjustment and Retraining Act (“WARN Act”), 29 U.S.C. §2101, under the Maine Severance Pay statute and for unpaid wages pursuant to 26 M.R.S.A. §626. The Superior Court

(Calkins, J.) granted partial summary judgment in favor of plaintiff, holding that three out of four of Viking’s Maine terminals (Sidney, Portland and Presque Isle) were not “covered establishments” under the Severance Pay Statute. See Order, July 27, 1998. Justice Calkins also dismissed Defendants’ claim for unpaid wages. Id. Remaining in this suit are the severance pay claims of those Defendants who worked in Bangor or those Viking employees who “primarily worked out of the Bangor facility to such an extent that the employee should be considered an _ employee of the Bangor facility,” Order at 8-9, and their WARN Act claims. Plaintiff and Defendants have filed cross-motions for summary judgment on these issues.

I. SEVERANCE PAY

If a company closes a facility that is a “covered establishment,” it is liable for severance pay for employees of the covered establishment under 26 M.R.S.A. §625- B!. That section defines “covered establishment” as “any industrial or commercial facility or part thereof which employs or has employed at any time in the preceding 12-month period 100 or more persons.” Id. (emphasis added) In her July 27, 1998 Order (“Order”), Justice Calkins held that only Viking’s Bangor operations could possibly constitute a “covered establishment” under the statute, since Bangor was the only location that arguably employed over 100 employees during the year prior to closing.

The issue was not raised and therefore Justice Calkins did not address

whether separate buildings operated by Viking within the same city should be

1 Section 625-B(2) states: Any employer who relocates or terminates a covered establishment shall be liable to his employees for severance pay at the rate of one week’s pay for each year of employment by the employee in that establishment.

2 considered one facility or separate facilities. At issue currently is whether the Bangor operations should be considered one “facility” for purposes of determining liability as a covered establishment.

The three buildings that make up the Bangor “site” are the terminal, the annex and the general office. Each should be examined separately to determine whether they were part of the same “facility.” See Order at 7, quoting Justice

_ Alexander’s opinion in Ewing v. Fort Halifax Packing Co., No. CV-81-516 (Ken. Cty.,

Oct. 29, 1982). For the Bangor operation to be considered a “covered establishment,” Defendants must succeed twice. First, all three of Viking’s Bangor buildings would have to be considered one “facility.” No combination of two of the buildings would bring the number of employees at Bangor over 100. Plaintiff's Statement of Material Facts (”PSMF”) 912. Furthermore, Defendants have to show that the Bangor site employed over 100 people within a year of the termination of operations.

A. Legislative Intent

The intent of the severance pay statute is to compensate a large number of

workers within a community who abruptly lose their jobs. See L.D. 424, Statement of Fact (105th Legis. 1971)*. When a group of one community’s employees is suddenly unemployed, the community must be able to absorb the impact of the unemployment, Id. The statute seeks to soften the blow to a community faced with such a situation. Id.

The number of employees specified in the statute serves the purpose of furthering this legislative intent. The Legislature determined that any community . that lost 100 jobs from the same employer within a year needs some help.

B. Integration of the Three Buildings

In order to apply the legislative intent, the three judges who have interpreted the meaning of “covered establishment” have developed an “integration” paradigm, in which buildings’ proximity and function are analyzed for similarities.

See Order at 6-8 (Calkins, J.); see also Faloon v. W.S. Libbey Co., No. CV-91-158 (And.

Cty. Nov. 24, 1992) (Lipez, J.) (“although the word ‘facility’ may sometimes connote a single location, a ‘single location’ definition of facility makes no sense when an

employer operates an integrated group of facilities in one city”); Director of Bureau

of Labor Standards v. Fort Halifax Packing Co., 510 A.2d 1054, 1064 (Me. 1986)

(upholding severance pay to employees not stationed in covered establishment but

2 26 M.R.S.A. §625-B was originally enacted as 26 M.R.S.A. §625. The severance pay provision was added in 1971. The Statement of Fact accompanying that enactment states:

Employers of large numbers of employees have closed their businesses without notification to their employees of the impending closedown.

Such lack of notice enhances a period of economic recession which invariably results in a community where large numbers of people simultaneously lose their jobs.

This bill would alleviate the adverse economic impact upon the employees and the community in which they live.

4 who performed jobs “essential” to functions of covered establishment and who lost

their jobs aa a result of closing of covered establishment), aff’g Ewing v. Fort Halifax

Packing Co., No. CV-81-516 (Ken. Cty. Oct. 29, 1982) (Alexander, J.).

The various functions of the annex, general office and terminal must be studied to gain perspective on whether Viking’s Bangor operations are sufficiently integrated to be considered one “facility.”

As a threshold matter, it can be determined that the annex and general office should be considered the same “facility,” even though the annex was located 2/10 of a mile down the road from the general office. Stipulation, [8. The general office and annex performed virtually the same functions, and the annex was created to contain the overflow from the general office once the general office became too crowded for the operations conducted there. Id. Both the general office and the annex closed in September of 1996. Stipulation, 957.

The terminal and general office were located on “a single piece of real estate.” Stipulation, 13. The terminal employees provided service to company vehicles used by employees of the general office. Stipulation, 128.

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