Mealey's (August 27, 2019, 1:30 PM EDT) -- NEW YORK — An employer seeking unpaid pension fund contributions in an Employee Retirement Income Security Act case did not bind itself to a trust agreement and the interest rate established under a delinquency policy until the employer agreed to a memorandum of agreement (MOA) modifying a collective bargaining agreement (CBA), the Second Circuit U.S. Court of Appeals held Aug. 20, vacating a lower court’s judgment and remanding for a redetermination of damages (The 32BJ North Pension Fund and its board of trustees v. Nutrition Management Services Co., Nos. 18-0857 and 18-1843, 2nd Cir., 2019 U.S. App. LEXIS 24716)....