Coles Express v. New England Teamsters & Trucking Industry Pension Fund

Summary

The court accepted the magistrate judge’s recommended disposition and held that Coles Express’s dispute over the date and amount of withdrawal liability under ERISA and the MPPAA had to proceed through arbitration before judicial review. The court also held that Coles Express’s objections to the recommendation were timely because service was made by mail. The action for declaratory relief was dismissed without prejudice, while the Fund’s counterclaim for interim payments was denied.

Holdings

1. The objections were timely because the ten-day objection period excludes intervening weekends and legal holidays, and the three days added for service by mail under Federal Rule of Civil Procedure 6(e) enlarge the filing period rather than merely overlap with the ten-day period.
2. After review by the plan sponsor, a continuing dispute concerning the interaction of the MPPAA's complete-withdrawal provision and its labor-dispute exception must be resolved through arbitration in the first instance.
3. The statutory-interpretation nature of the dispute did not permit Coles Express to bypass arbitration because the case involved the MPPAA provisions within section 1401's express scope, lacked a stipulated factual record, and presented circumstances in which arbitration would promote judicial economy.

Questions Presented

1. Whether Coles Express's objections to the magistrate's recommended disposition were timely when the recommendation was served by mail.
2. Whether a dispute concerning the interaction between the MPPAA's complete-withdrawal provisions and its labor-dispute exception must be submitted to arbitration before a federal district court may resolve it.
3. Whether the fact that the dispute presented primarily statutory-interpretation questions permitted Coles Express to bypass the MPPAA's arbitration procedure.

Disposition

dismissed