ThurberThurber Finally, although some courts have reached a contrary result, see Dohrer v. Wakeman, supra; Melang v. I. B. E. W. Pac. Coast Pension Fund, supra; Kennet v. U. M. W., 183 F. Supp. 315, 318 (D.D.C. 1960), and there are strong arguments on the other side, plaintiff's contention that a sole proprietor can be considered an "employee" as that word is used in section 302(c)(5) is not frivolous. The Supreme Court has indicated that the word "employee" in the LMRA may vary in scope depending on the policies of the specific LMRA section in question where inclusion or exclusion is not totally clear. See Allied Chemical Workers v. Pittsburgh Plate Glass Co., 404 U.S. 157, 92 S.Ct. 383, 30 L.Ed.2d 341 (1971).
May's claim that Corley lacks standing to bring an action on behalf of the plan is not supported by District of Columbia case law. See Kennet v. United Mineworkers of America, 183 F. Supp. 315, 317 (D.D.C. 1960). 2.