Fourth Circuit Holds That “Contingent” Proof of Claim Did Not Trigger Statute of Limitations to Collect Withdrawal Liability

In International Painters and Allied Trades Industry Pension Fund v. Florida Glass of Tampa Bay, Inc., 2026 WL 191344 (4th Cir. Jan. 26, 2026, No. 25-1312), the Fourth Circuit held that the “contingent” proof of claim a multiemployer pension plan filed in a contributing employer’s bankruptcy did not constitute a “notice and demand” triggering the statute of limitations to collect withdrawal liability from the employer’s controlled group members.... By: Proskauer - Employee Benefits & Executive