Brandon Osbahr et al. v. Plumbing Contractors, Inc.

Summary

The United States District Court for the Western District of Tennessee granted Plaintiffs’ motion for default judgment against Plumbing Contractors, Inc. in an ERISA action involving unpaid contributions, dues, and fees owed to union-established funds. The court awarded $184,544.79, including unpaid contributions, liquidated damages, late charges, attorney’s fees, and costs.

Holdings

1. The court may grant default judgment in its sound judicial discretion when the defendant has failed to respond, the Clerk has entered default, and the well-pleaded allegations establish liability.
2. Default established Defendant's liability, but Plaintiffs were required to prove the amount of unliquidated damages; Plaintiffs satisfied that requirement through their calculations, supplemental briefing, and affidavits.
3. Plaintiffs were entitled to $184,544.79, consisting of unpaid contributions and dues, liquidated damages, attorney's fees, and costs.

Questions Presented

1. Whether Plaintiffs were entitled to default judgment under Federal Rule of Civil Procedure 55(b)(2) after Defendant failed to respond and the Clerk entered default.
2. Whether Plaintiffs adequately proved and reasonably calculated the amount of damages, liquidated damages, attorney's fees, and costs recoverable under ERISA § 502(g)(2).

Disposition

other