Boards of Trustees of the Ohio Laborers Benefits v. Ady Excavating LLC

Summary

The United States District Court for the Southern District of Ohio considers Plaintiffs’ renewed motion for default judgment in an action seeking delinquent fringe benefit contributions under ERISA and related agreements. The court awards principal contributions, liquidated damages, simple interest, attorney’s fees, and costs, while disallowing compound interest and additional fees and costs associated with renewing the motion.

Holdings

1. Defendant's default admitted the well-pleaded factual allegations, which established Defendant's liability for breach of the contribution agreements and delinquent contributions under ERISA.
2. Plaintiffs proved entitlement to $30,088.59 in principal, $3,324.13 in liquidated damages, and $7,888.58 in simple interest, but did not prove entitlement to the larger amount of compound interest claimed.
3. Plaintiffs could not recover the additional $1,332.50 in attorney's fees and $55.23 in costs incurred after the original motion because those amounts resulted from renewing an inadequately supported motion rather than from Defendant's breach.

Questions Presented

1. Whether Defendant's default and the unchallenged allegations established liability for breach of the contribution agreements and delinquent contributions under ERISA.
2. Whether Plaintiffs proved entitlement to the requested principal, liquidated damages, interest, attorney's fees, and costs.
3. Whether Plaintiffs could recover compound interest under plan rules adopted after the relevant contribution delinquencies.
4. Whether attorney's fees and costs incurred in renewing an inadequately supported default-judgment motion were attributable to Defendant's breach.

Disposition

other