It claimed probationary employees were wrongly counted – but couldn't name one
A healthcare employer's own payroll records sealed its fate in an $800,000-plus pension dispute after a federal court threw out both of its defenses.
On March 12, 2026, the U.S. District Court for the District of Columbia ruled against Hamilton Park OPCO, LLC, which operates as Alaris Health at Hamilton Park, granting summary judgment in favor of the Service Employees International Union National Industry Pension Fund and its Trustees.
The Fund, a multiemployer employee pension plan, sued Hamilton Park for failing to make supplemental pension contributions required under a collective bargaining agreement with the Service Employees International Union Local 1199 United Health Care Workers East. The contributions were owed under the Employee Retirement Income Security Act of 1974 and its subsequent amendments, including the Pension Protection Act of 2006 and the Multiemployer Pension Reform Act of 2014.
The roots of the dispute trace back more than a decade. Hamilton Park OPCO purchased its predecessor entity, Hamilton Park Healthcare Center, LTD., in December 2012 and, in April 2013, agreed to be bound by the existing CBA, along with a 2012 arbitration decision known as the Scheinman Award, which extended the agreement through June 30, 2016. Under the CBA, the employer was required to contribute 2.75% of gross earnings for each covered employee beginning on that employee's ninetieth day of employment. On top of that, the Fund's rehabilitation plan called for escalating supplemental contributions under a Preferred Schedule, with rates climbing from 10% in 2010 to 169.4% in 2022.
Hamilton Park pushed back on two fronts.
It first argued that the Fund's damages figures wrongly included probationary employees who had worked fewer than 90 days and were not yet eligible for contributions. The court was unconvinced. The Fund had calculated damages using payroll spreadsheets that Hamilton Park itself created and handed over during discovery. Those spreadsheets broke down each employee's earnings into eligible and ineligible categories, and the Fund used only the eligible figures. Hamilton Park offered no declaration, no alternative calculation, and could not point to a single probationary employee it believed was improperly counted.
Its second argument targeted the supplemental contribution rate for the year beginning July 1, 2015. The Scheinman Award had spelled out rates for 2012, 2013, and 2014 – but was silent on 2015, even though the agreement remained in effect. Hamilton Park argued that the previous year's rate should have simply carried over. The court disagreed, finding that the rehabilitation plan and the statute itself required the Preferred Schedule to stay in effect for the full life of the agreement once adopted. The court also noted that while the Scheinman Award gave the union the option to reopen and negotiate wages and other terms for the final year, the union never exercised that right – making any debate over what the parties might have agreed to beside the point.
The court took care to distinguish the outcome from a similar case it had decided earlier. In the Castle Hill case, the Fund had failed to identify the legal basis for applying the Preferred Schedule to an unspecified year. This time, the Fund came armed with the specific language from both the rehabilitation plan and the statute.
The financial picture was straightforward. Hamilton Park paid $560,118.79 into the Fund over the relevant period, enough to cover its base contributions of $515,742.82. But it fell well short of the supplemental contributions owed, which totaled $393,657.80. The court awarded $349,281.83 in unpaid supplemental contributions, along with interest and liquidated damages.
The ruling carries a practical reminder for HR teams, particularly those managing benefits in unionized workplaces or navigating employer transitions: payroll records matter, contribution obligations under multiemployer pension plans do not pause when a CBA goes silent on specifics, and failing to keep clean documentation can leave an employer with no ground to stand on in court.
