Board of Trustees, Sheet Metal Workers' National Pension Fund, et al. v. Superior Air, Inc.

Summary

A United States magistrate judge recommends granting the plaintiffs’ motion for default judgment against Superior Air, Inc. for delinquent employee-benefit contributions allegedly owed under collective bargaining agreements. The proposed findings address jurisdiction, service, default, liability under ERISA and the LMRA, and damages. The recommended judgment totals $61,908.64, including contributions, interest, liquidated damages, audit fees, attorneys’ fees, and costs.

Holdings

1. A defendant's properly entered default admits the well-pleaded factual allegations of the complaint, except allegations concerning damages, but the court must still determine whether those allegations state a claim and must independently establish damages.
2. The court had subject matter jurisdiction under 28 U.S.C. § 1331 and 29 U.S.C. § 1132(e)(1), personal jurisdiction based on ERISA's nationwide service provision, and proper venue in the Eastern District of Virginia.
3. Superior Air was properly served through its registered agent and default was properly entered after it failed to file a responsive pleading within the Rule 12(a) period.
4. The admitted allegations and supporting evidence established Superior Air's liability under ERISA § 515 and LMRA § 301 for failing to make contributions required by the applicable collective bargaining agreements.
5. Plaintiffs established entitlement to $56,362.40 in contributions, interest, liquidated damages, and audit fees, plus $5,546.24 in reasonable attorneys' fees and costs, for a recommended total default judgment of $61,908.64.

Questions Presented

1. Whether the court had subject matter and personal jurisdiction and proper venue over the ERISA and LMRA claims.
2. Whether Superior Air was properly served and defaulted after failing to plead or otherwise defend.
3. Whether the admitted allegations and supporting evidence established liability for unpaid contributions under ERISA and the LMRA.
4. Whether Plaintiffs established entitlement to contributions, interest, liquidated damages, audit fees, attorneys' fees, and costs.
5. Whether the recommended default judgment complied with Federal Rule of Civil Procedure 54(c).

Disposition

other