Mine Workers v. Robinson
Annotate this Case
455 U.S. 562 (1982)
U.S. Supreme Court
Mine Workers v. Robinson, 455 U.S. 562 (1982)
United Mine Workers of America
Health & Retirement Funds v. Robinson
Argued January 13, 1982
Decided March 8, 1982
455 U.S. 562
A 1974 collective bargaining agreement between the United Mine Workers of America and the Bituminous Coal Operators' Association increased health benefits, payable out of a trust fund financed by contributions from the operators, for widows of coal miners who died prior to the effective date of the agreement and who were receiving pensions when they died, but did not increase such benefits for widows of miners who died prior to the effective date and were still working at the time of death, even though they were eligible for pensions. Respondents, widows of miners who died in 1967 and 1971, respectively, and were eligible for pensions but were still working at the time of their deaths, brought a class action in Federal District Court against the trustees of the fund, alleging that the requirement that a miner be receiving a pension at the time of his death in order to make his widow eligible for the increased health benefits had no rational relationship to the purposes of the trust fund, and therefore was illegal under § 302 of the Labor Management Relations Act. The District Court denied relief. The Court of Appeals reversed, holding that § 302(c)(5), which requires jointly administered pension trusts to be maintained "for the sole and exclusive benefit of employees . . . and their families and dependents," means that eligibility rules fixed by a collective bargaining agreement must meet a reasonableness standard, and that, in this case, the trustees were unable to produce an acceptable explanation for the discrimination between widows of pensioners and widows of pension-eligible miners.
Held: Section 302(c)(5) does not authorize federal courts to review for reasonableness the provisions of a collective bargaining agreement, such as the provisions in question, allocating health benefits among potential beneficiaries of an employee benefit trust fund. Pp. 455 U. S. 570-576.
(a) Section 302(c)(5)'s language embodies no reasonableness requirement. Its plain meaning is simply that employer contributions to employee benefit trust funds must accrue to the benefit of employees and their families and dependents, to the exclusion of all others. P. 455 U. S. 570.
(b) This reading is amply supported by the legislative history, which indicates that § 302(c)(5) was meant to protect employees from the risk
that funds contributed by their employers for the benefit of the employees and their families might be diverted to other union purposes, or even to union leaders' private benefit. Pp. 455 U. S. 570-572.
(c) Such interpretation is also supported by § 302(c)(5)'s other requirements prescribing the conditions that must be satisfied to exempt employer contributions to pension funds from a criminal sanction. P. 455 U. S. 572.
(d) Absent conflict with federal law, the trustees here breached no fiduciary duties in administering the trust fund in question in accordance with the 1974 collective bargaining agreement. Pp. 455 U. S. 573-574.
(e) When neither the collective bargaining process nor its end product violates any command of Congress, a federal court has no authority to modify the substantive terms of a collective bargaining contract. Pp. 455 U. S. 574-576.
205 U.S.App.D.C. 330, 640 F.2d 416, reversed.
STEVENS, J., delivered the opinion for a unanimous Court.