Office and Professional Employees Insurance Trust Fund v. Laborers Funds Administrative Office of Northern California, Inc.

Laborers Fund Corporation (“Laborers”) appeals the district court’s grant of summary judgment in favor of the Office & Professional Employees Insurance Trust Fund (“OPEIT”), awarding unpaid trust contributions, interest, attorneys’ fees and costs. Laborers argues that the award, by requiring that Laborers pay a higher rate of contribution on behalf of its employees, illegally imposes a new contract term where no new collective bargaining agreement (“CBA”) had been reached. OPEIT argues that the award merely maintains the status quo by enforcing the “maintenance of benefits” provision of the expired CBA. Because there was no subject matter jurisdiction over OPEIT’s claim, we reverse and remand to the district court.

FACTUAL AND PROCEDURAL BACKGROUND

In 1977, Laborers, previously a member of a multi-employer bargaining unit, entered into a separate CBA with the Office & Professional Employees Union Local No. 3 (“Local 3”). The CBA, which was valid through October 31, 1979, required Laborers to make monthly contributions to OPEIT for health and welfare coverage of employees subject to the CBA. The CBA included a “maintenance of benefits” clause, under which Laborers “agree[d] to…