ERISA-Second Circuit Rules that Claims By A Medical Fund Against Another Fund For Unpaid Contributions Are State Law Breach-Of-Contract Claims, Rather Than Claims Under ERISA

In Silverman, Trustee of the Union Mutual Medical Fund v. Crowley, Docket Nos. 13‐392‐cv(L), 13‐1175‐cv(XAP) (2nd Cir. 2014), the Teamsters Local 210 Affiliated Health and Insurance Fund (the “210 Fund”) and its trustees appeal from a judgment of the district court, which awarded approximately $2.5 million to the Union Mutual Medical Fund (“UMM Fund”) for unpaid ERISA plan contributions.

In analyzing the case, the Second Circuit Court of Appeals (the “Court”) said that, since the 210 Fund was not obligated to contribute funds to the UMM Fund under the terms of an ERISA plan (such contributions were required under a collective bargaining agreement, which is not an ERISA plan), the district court lacked subject matter jurisdiction under ERISA over the claims on which the UMM Fund prevailed. However, because these claims can be construed as state law breach‐of‐contract claims, the Court vacated and remanded the case back to the district court to decide, in the first instance, whether to exercise supplemental jurisdiction and decide the claims under this alternative theory.

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