Arkansas Pipe Trades Health and Welfare Fund v. Stiles Consulting Firm, LLC

Summary

The United States District Court for the Central District of California granted plaintiffs’ motion for default judgment against Stiles Consulting Firm, LLC and Corey Stiles. The court found liability under ERISA for delinquent employee benefit contributions and awarded $54,631.75, consisting of unpaid contributions, interest, liquidated damages, attorneys’ fees, and costs.

Holdings

1. Plaintiffs satisfied the requirements of Federal Rules of Civil Procedure 54(c) and 55 and Central District of California Local Rules 55-1 and 55-2, including proof of service, entry of default, and the inapplicability of the Servicemembers Civil Relief Act.
2. The Eitel factors weighed in favor of entering default judgment against Defendants.
3. Plaintiffs sufficiently established that Stiles Consulting violated ERISA § 515 by failing to submit required reports and pay contributions for Union employees, and that Corey Stiles was liable as the company's alter ego.
4. Plaintiffs adequately supported an award of $19,500.75 in unpaid contributions, $1,744.79 in liquidated damages, $1,377.13 in prejudgment interest, $29,563.75 in attorneys' fees, and $2,445.33 in costs, for a total award of $54,631.75.

Questions Presented

1. Whether Plaintiffs satisfied the procedural requirements for entry of default judgment under Federal Rules of Civil Procedure 54(c) and 55 and the Central District of California's local rules.
2. Whether the Eitel factors supported entry of default judgment against Defendants.
3. Whether Plaintiffs sufficiently established liability under ERISA § 515 for delinquent employee-benefit contributions, including Corey Stiles's liability as the alter ego of Stiles Consulting.
4. Whether Plaintiffs submitted sufficient evidence to support unpaid contributions, interest, liquidated damages, attorneys' fees, and costs.

Disposition

other