CBA Records Audit Includes Non-Union Payroll Information
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CBA Records Audit Includes Non-Union Payroll Information

Trustees of union employee benefit funds governed by the Employee Retirement Income Security Act (ERISA) filed an action alleging the defendant improperly refused to turn over requested payroll information of its non-union employee as part of the plaintiff's audit. The audit was sought under the parties’ collective bargaining agreement (CBA). The Seventh Circuit reversed summary judgment for the employer holding the trustees were authorized to conduct random audits of the employer's payroll records for both union and non-union employees under the terms of the CBA, so the records had to be produced.

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