## Facts

- Multiple St. Louis produce wholesalers were parties to collective-bargaining agreements (CBAs) with a Teamsters local and participated in a multiemployer pension plan administered by Central States.
- The CBAs required pension contributions for “regular employees” but expressly excluded “casual employees” from benefit coverage.
- Pre-1982 CBAs described casuals as hired as needed, imposed an 80-hours-per-month cap, and restricted casual use to replacing regular employees without increasing the workforce.
- Post-1982 CBAs retained the exclusion of casuals from benefits but removed the hour cap and the replacement-only restriction.
- Central States believed “casual” meant workers employed sporadically or intermittently, and asserted that workers regularly working full-time schedules could not be treated as casuals for contribution purposes.
- After audits and investigation, Central States alleged employers misclassified employees as casuals to avoid pension contributions and sued under ERISA for delinquent contributions, interest, and statutory add-ons.
- Trial evidence showed employers commonly hired workers as casuals (sometimes working full-time), some later became regulars when vacancies opened, employees knew their status at hire, and the union shared the employers’ understanding of the casual category.

## Issues

1. Whether ERISA required employers to make pension contributions for workers labeled “casual” in the CBAs when those workers in practice worked regular or full-time schedules.
2. Whether a multiemployer pension fund may disregard the bargaining parties’ agreed classification of noncovered “casual employees” and impose a different, hours-based definition to expand contribution obligations.

## Decision

- The Eighth Circuit affirmed judgments for the employer-defendants.
- The court held the employers had no ERISA obligation to contribute for employees classified as “casual” under the CBAs, even if those employees worked full-time hours, absent fraud, collusion, or sham arrangements.
- The court rejected the Fund’s attempt to substitute its own definition of “casual” for the definition reflected in the CBAs and the parties’ course of dealing.

## Legal Principles

- An employer’s ERISA contribution duty to a multiemployer plan is determined by the written terms of the applicable CBA (and related governing plan documents) and does not extend beyond what the employer agreed to pay.
- Where a CBA expressly excludes a category of employees from benefit coverage, a fund generally cannot collect contributions for that category by recharacterizing workers contrary to the negotiated classification.
- Courts will not override the bargaining parties’ allocation of covered and noncovered employees based solely on similarity of work performed or hours worked; ERISA enforces promised contributions rather than mandating equal coverage across similarly situated workers.
- Absent proof of fraud, collusion, misrepresentation, or a sham classification designed to defeat contractual obligations, a fund cannot expand contribution liability beyond the CBA through unilateral interpretive standards.

## Conclusion

The Eighth Circuit held that Central States could not recover delinquent contributions for workers the employers and union treated as noncovered “casual employees” under the CBAs, even when those workers worked regular or full-time hours, because ERISA ties contribution liability to the parties’ contractual commitments absent fraud or collusion.


Cent. States, Se. & Sw. Areas Pension Fund v. Indep. Fruit & Produce Co., 919 F.2d 1343 (8th Cir. 1990)