A multiemployer plan that prevails in an action to collect delinquent contributions or withdrawal liability is statutorily entitled to recover reasonable attorneys’ fees and costs “of the action.” In International Painters & Allied Trades Industry Pension Fund v. Florida Glass of Tampa Bay, Inc. , No. 23-cv-00045, 2025 WL 712965 (D. Md. Mar. 5, 2025), the court held that the statute permits a plan to recover not just the fees and costs incurred in the collection action, but also those incurred to defend a related action.

Florida Glass of Tampa Bay, Inc. was a contributing employer to the International Painters and Allied Trades Industry Pension Fund. Following Florida Glass’s complete withdrawal from the Fund, the Fund filed suit to collect over $1.5 million in withdrawal liability from

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