Action to recover unpaid benefit contributions under the Retirement Income Security Act & the Labor Management Relations Act; Whether defendant’s Full-Service Maintenance Technicians (FMTs) performed work covered by the relevant collective bargaining agreement (CBA), triggering defendant’s obligation to pay plaintiffs-Funds for the hours the FMTs worked; Whether the CBA’s title was dispositive of who was covered under the CBA; Brotherhood of RR Trainmen v Baltimore & OH RR Co; Whether the CBA’s “substantive provisions” were ambiguous; United States v Cain; Tonguette v Sun Life & Health Ins Co (Unpub 6th Cir)

[This appeal was from the WD-MI.] The court concluded that questions remained whether certain employees were covered under the relevant CBA, and that the district court should have considered whether the CBA’s “substantive provisions” were ambiguous before basing its decision on who was covered on a caption in the CBA. Thus, the court reversed summary judgment for defendant-Pro Services. Plaintiffs, the trustees of three multi-employer benefit funds, sued to recover unpaid benefit contributions. Pro Services is an industrial contractor in Michigan that supplies skilled-trade workers to both the construction and manufacturing industries. The issue on appeal was whether the work of the employees at issue, FMTs, was covered under the CBA, triggering Pro Services’ payment obligation to the Funds. The district court granted Pro Services summary judgment on the basis the CBA’s caption stated that it covered “the construction industry” and it was undisputed the FMTs worked in manufacturing. The court first considered the part that “titles” play when determining a contract’s meaning. Under Trainmen, headings and titles are only of use when there is some ambiguity in what the text provides. They “‘are not meant to take the place of the detailed provisions of the text,’ and they ‘cannot limit the plain meaning of the text.’” The court held that the CBA’s “plain meaning is that the Agreement covers all employees of Pro Services engaged in the sheet metal work described, regardless of industry, and regardless of whether they work in ‘manufacture,’ ‘installation,’ or ‘repairing and servicing[.]’” Because some questions remained “as to how much covered work the FMT’s” actually performed, summary judgment was inappropriate. Remanded.