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Trustees of Ohio Bricklayers Pension Fund v. Skillcraft Systems of Toledo, Inc.
Citation: 99 F. App'x 600Docket: No. 02-4328
Court: Court of Appeals for the Sixth Circuit; May 13, 2004; Federal Appellate Court
Two benefit funds, acting as ERISA plan administrators for Bricklayers and Allied Craftsmen Local No. 46, sued Skillcraft Systems of Toledo, Inc. under ERISA and the Labor and Management Relations Act, claiming Skillcraft failed to make contributions required by an extension of a collective bargaining agreement. This agreement, which bound subcontractors like Skillcraft, had been sent to the company for execution. Skillcraft employee Gail Mitchell, described variously as a secretary and office manager, filled out and returned the agreement form but lacked apparent authority to bind Skillcraft to the contract. The district court granted summary judgment to Skillcraft, concluding that Mitchell did not have the necessary authority and that the Funds could not recover under a detrimental reliance theory. The Funds appealed, but the appellate court affirmed the lower court's decision. It found no legal basis for claiming Mitchell had actual authority, nor did the record support a finding of apparent authority, as defined by a precedent case (Anderson v. Int’l Union). The court noted that Skillcraft had not manifested that Mitchell was its agent for executing the collective bargaining agreement, and the Funds provided no evidence that they were aware she had filled out the form prior to litigation. The lack of a signature line for an authorized representative further complicated the claim, and it was emphasized that allowing any employee to bind a company to a contract based solely on routine business practices would be unreasonable. Additionally, there was no communication between the union and Skillcraft regarding the agreement, and the form's format was deemed confusing. The form in question includes a line labeled 'Authorized Representative and Title,' but it also features a signature line for the union official and a typed union name, indicating a requirement for a signature rather than just a designation. There is an additional space for a witness signature below the union signature line, while no corresponding witness signature line exists for the company’s official. This absence weakens the plaintiffs' argument regarding apparent authority. The plaintiffs also contend that Skillcraft should be held to the collective bargaining agreement based on the doctrine of promissory estoppel, which requires five elements: representation of material facts, awareness of true facts by the party to be estopped, intent for the representation to be acted upon, lack of awareness of true facts by the party asserting estoppel, and detrimental reliance on the representation. However, the district court found that the first two elements were absent, as Mitchell, not Skillcraft, was responsible for the relevant conduct and had awareness of the true facts. Additionally, the court concluded that the record did not support the third element, leading to a determination that plaintiffs could not succeed on a detrimental reliance theory. As there was no binding contract between the parties, the district court's decision to grant summary judgment to the defendant was affirmed, making it unnecessary to consider the defendant’s argument regarding contributions to a separate ERISA fund.