Riverstone Group, Inc. v. Midwest Operating Engineers Fringe Benefit Funds

Dist. Ct. did not err in granting plaintiff-employer’s motion for summary judgment in action seeking declaration that it had no obligation to make contributions to employees’ pension fund on behalf of individuals hired after collective bargaining agreement that required plaintiff to make said pension payments had expired. It also did not err in finding that it did not have jurisdiction to consider defendant-pension fund’s counterclaim seeking unpaid pension fund contributions from plaintiff, where: (1) no contractual provision requiring said payments was in existence, and (2) in absence of contractual agreement, any failure to make said payments could only constitute violation of section 8(a)(5) of National Labor Relations Act (NLRA), which is under NLRB’s exclusive jurisdiction. Ct. rejected defendant’s argument that Dist. Ct. had jurisdiction to consider its counterclaim seeking pension payments under either section 301 of Labor Management Relations Act arising out of plaintiff’s continuing obligation to maintain status quo while negotiating new contract or under sections 502 and 515 of ERISA, where both potential claims intruded into domain of unfair labor practices under section 8(a)(5) of NLRA.