"The Seventh Circuit is not alone in finding that an employer's contractual obligations to participate in multiemployer funds can survive decertification, withdrawals of recognition, and disclaimers of interest. But there is a competing view. The Ninth Circuit has recognized that when a bargaining unit ceases to exist, be it by decertification or contract repudiation given the existence of a one-person bargaining unit, any existing contract becomes void, not voidable, ending the employer's obligation to contribute to employee benefit plans." [Midwest Operating Engineers Welfare Fund v. Cleveland Quarry, Nos. 15-2628, 15-3221, 15-3861, 16-1870 (7th Cir. Dec. 20, 2016)]  MORE >>