Board of Trustees of the Western Conference of Teamsters Pension Trust Fund v. H.F. Johnson, Inc.

The Board of Trustees of the Western Conference of Teamsters Pension Trust Fund (The Fund) appeals the district court’s decision 1) that joint venturers may not be held personally liable for their business’s withdrawal obligations under the Multiemployer Pension Plan Amendments to the Employee Retirement Income Security Act (ERISA), and 2) that the Montana non-claim statute governing actions against decedents’ estates bars the Fund’s action to collect withdrawal liability under ERISA from the estate of a deceased joint venturer. We reverse the judgment on both issues.

I

Background

The Fund is a multiemployer pension fund, administered under ERISA, 29 U.S.C. § 1001 et seq., for the benefit of employees represented by the Western Conference of Teamsters. Employers participating in the Fund must pay regular contributions based on wages earned and hours worked by employees.

The Fund in this case is a “defined benefit” fund. In such funds, benefits vested in employees typically exceed total contributions made by an employer on behalf of those employees. See Connolly v. Pension Benefit Guaranty Corp., 581 F.2d 729, 733 (9th Cir.1978), cert. denied, 440 U.S. 935 , 99 S.Ct. 1278 , 59…