Dubuque Packing Co.

United States Court of Appeals for the Eighth Circuit · Labor Law

Labor Lawplan interpretationboard of administrationjurisdictioncollective bargaining agreementtermination noticecompany contributionsactuarial methods

Facts

The plan's section 9.4(c) gives the Board of Administration power to interpret plan provisions and reflects the parties' agreement to submit disputes to the Board. Two disputes existed: one concerning the effectiveness of a termination notice and another concerning the Company's contributions under the plan. The parties disputed how the plan's provisions interacted with an extension of the collective bargaining agreement to October 1983 and whether sections 3.1 and 9.4(b) prevented termination until all benefits were fully funded. They also disputed whether the Board could review actuarial methods used to determine contributions or could act only when the Company was in default of amounts defined as due by the actuary.

Issue

Whether, under section 9.4(c) of the plan, the Board of Administration has authority to resolve the disputes over the effectiveness of termination and over the scope of its jurisdiction regarding the Company's contributions, including whether it may review actuarial methods.

Rule

A plan provision that grants a board authority to interpret plan provisions and embodies the parties' agreement to submit disputes to that board delegates to the board contract-interpretation questions arising under the plan, including questions bearing on the effectiveness of termination and on whether the board has jurisdiction over a contribution dispute. If the contract is susceptible of either interpretation, the board must decide which interpretation is correct under the delegated authority.

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In Omaha, Nebraska, Prairie River Foundry and Local 214 jointly administer a pension plan. The plan states that the Board of Administration may "interpret all provisions of this Plan" and that disputes arising under the plan shall be submitted to the Board. After the parties extend their collective bargaining agreement for six months, the employer insists its earlier notice ended the plan on the original date, while the union argues the extension postponed termination under the plan's termination clause.

Who should decide whether the bargaining agreement extension affected the effectiveness of the termination notice?

Explanation. Where the plan expressly gives the board authority to interpret plan provisions and reflects the parties' agreement to submit disputes to the board, questions about the effectiveness of termination that depend on reading plan language are for the board. The majority treated the effect of a bargaining-agreement extension on the termination provision as a contract-interpretation issue delegated to the board. (Derived from Dubuque Packing Co. (n.d.).)