Board of Trustees of the Employee Painters' Trust v. Wrightway Mechanical, LLC, an Idaho limited liability company, et al.

CourtDistrict Court, W.D. Washington
DecidedOctober 30, 2025
Docket2:25-cv-00619
StatusUnknown

This text of Board of Trustees of the Employee Painters' Trust v. Wrightway Mechanical, LLC, an Idaho limited liability company, et al. (Board of Trustees of the Employee Painters' Trust v. Wrightway Mechanical, LLC, an Idaho limited liability company, et al.) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Board of Trustees of the Employee Painters' Trust v. Wrightway Mechanical, LLC, an Idaho limited liability company, et al., (W.D. Wash. 2025).

Opinion

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5 6 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 7 AT SEATTLE 8 9 BOARD OF TRUSTEES OF THE CASE NO. 2:25-cv-00619 EMPLOYEE PAINTERS' TRUST, 10 ORDER ON MOTION FOR Plaintiff, 11 v. DEFAULT JUDGMENT 12 WRIGHTWAY MECHANICAL, LLC, an Idaho limited liability company, et al., 13 Defendants. 14

15 This is an action for damages and injunctive relief under the Employee Retirement 16 Income Security Act of 1974 (“ERISA”), 29 U.S.C. §§ 1001 et seq. This matter is before the 17 Court on Plaintiff’s Motion for Default Judgment. Dkt. No. 15. Having reviewed the motion and 18 the relevant record, the Court GRANTS Plaintiff’s motion. 19 I. BACKGROUND 20 This case concerns an employer’s failure to adhere to reporting requirements and failure 21 to make contributions to a labor-management employee-benefit trust (a “Taft-Hartley Trust”). 22 A. The Parties 23 Plaintiff is the Board of Trustees for The Employee Painters’ Trust (“Trust”), an “express 24 trust” created and operated pursuant to Section 302 of the Labor Management Relations Act 1 (“LMRA” or “Taft-Hartley Act”), 29 U.S.C. § 186(c), and ERISA. See Dkt. No. 1 (complaint) 2 ¶¶ 5–6. Plaintiff is a “fiduciary” of the Trust within the meaning of ERISA “with respect to 3 collection of contributions due to the Trust and related matters.” Id. ¶ 7 (citing 29 U.S.C. 4 §§ 1102(a), 1002(16), (21)). The Trust was created and is administered in Seattle, Washington.

5 Id. ¶ 8. 6 Defendants are Wrightway Mechanical, LLC (“Wrightway Mechanical”), an Idaho 7 limited liability company (id. ¶ 9), and Steven Wright (“Wright”), “the primary owner, member, 8 manager, governing person, officer, director, principal and/or key employee of Wrightway 9 Mechanical” (id. ¶ 14). Wright is responsible for Wrightway Mechanical’s adherence to and 10 performance of its obligations with respect to the Trust. See id. Plaintiff has also named as 11 Defendants 10 anonymous individual John Does and 10 anonymous Roe Corporations. Id. ¶ 15. 12 B. The Collective Bargaining Agreement and Trust Agreement

13 Labor–Management relations are governed by the Standard Form of Union Agreement 14 for Sheet Metal, Roofing, Ventilating and Air Conditioning Contracting Divisions of the 15 Construction Industry (“collective bargaining agreement” or “CBA”) between the Northwest 16 Regional Council of SMART,1 Local Union 55 (“Union”); and the Inland Northwest Sheet Metal 17 Contractors Association (“SMACNA”). Dkt. No. 1 ¶ 19. The Union “represent[s] employees in 18 the construction industry in the States of Washington, Idaho, and surrounding areas.” Id. ¶ 16. 19 SMACNA “is an employer association representing employers in the construction industry in the 20 States of Washington, Idaho, and surrounding areas.” Id. ¶ 18. In short, for collective-bargaining 21 purposes, the Union represents labor, and SMACNA represents management. Wrightway 22 Mechanical is a member of SMACNA. Id. ¶ 21. 23

24 1 Sheet Metal Air Rail Transportation Workers’ Union. 1 On October 11, 2016, Wrightway Mechanical signed the CBA, thereby agreeing to be 2 bound by its terms. Id. ¶¶ 19, 22. Under the CBA, Wrightway Mechanical also “agreed to be 3 bound to the Trust Agreement governing the Trust and the Policies and Procedures (“Policies”) 4 adopted by” Plaintiff. Id. ¶ 23. Among other things, the CBA defines “Covered Work,” which is

5 labor that obligates a signatory employer to contribute to the Trust and to submit to Plaintiff 6 “monthly written reports . . . showing all hours of work performed by its employees who perform 7 Covered Work . . . .” Id. ¶ 29. “[E]ven if no work was performed during a given work month,” 8 Wrightway Mechanical was still obligated “to submit these monthly remittance reports to 9 Plaintiff.” Id. The CBA, Trust Agreement, and Policies also obligate Wrightway Mechanical “to 10 properly pay to Plaintiff fringe benefit contributions to the Trust on a monthly basis and at 11 specified rates for each and every hour of work performed by its employees who perform 12 Covered Work.” Id. ¶ 30. Should Wrightway Mechanical fail to timely remit reports or 13 contributions to Plaintiff, the CBA, Trust Agreement, and Policies obligate Wrightway 14 Mechanical “to pay, in addition to the contributions owed, interest at the rate of twelve percent

15 (12%) and liquidated damages at the rate of one percent (1%) per month up to twenty percent 16 (20%) until paid for all contributions which are owed, or $100, whichever is greater.” Id. ¶ 32. 17 The CBA, Trust Agreement, and Policies also impose on Wrightway Mechanical record- 18 keeping obligations. See id. ¶¶ 34–35. Where Wrightway Mechanical fails to comply with these 19 obligations, “it shall be conclusively presumed that each employee of Wrightway Mechanical 20 was engaged in Covered Work for forty (40) hours in each week in which such employee 21 performed any Covered Work for Wrightway Mechanical.” Id. ¶ 36. “[F]ringe benefit 22 contributions due the Trust shall be computed based upon a forty (40) hour week.” Id. If 23 Wrightway Mechanical fails to maintain records “adequate and sufficient to readily identify all

24 1 types of hours of work performed by all of its employees,” there arises a rebuttable presumption 2 that all of the insufficiently documented work is, in fact, Covered Work. Id. ¶ 37. 3 The record-keeping provisions of the CBA, Trust Agreement, and Policies are 4 complemented by audit provisions, which requires Wrightway Mechanical to provide certain

5 records to an auditor upon request. Id. ¶ 35. If Wrightway Mechanical does not cooperate with an 6 audit “such that the Auditor is unable to determine the amount of covered hours worked by the 7 employees, determine the amount of contributions owed to the Trust, or determine the benefits 8 due or which may become due,” the Trust may deem Wrightway Mechanical’s “average annual 9 contributions to the Trust for the previous three (3) years, or $100,000, whichever is greater,” to 10 be “unremitted contributions for each year covered by the Audit Period.” Id. ¶ 38. If an audit 11 “reveals an underpayment or deficiency in reporting or payment of contributions, the CBA, Trust 12 Agreement, and Policies require Wrightway Mechanical to pay to the Trust the underpaid 13 contributions, plus accrued interest, liquidated damages, audit fees, attorney’s fees, and costs.” 14 Id. ¶ 40.

15 Finally, should Plaintiff need to retain legal counsel because of Wrightway Mechanical’s 16 delinquencies with respect to Trust contributions, or to “compel Wrightway Mechanical to 17 furnish . . . , or permit the examination of[,] books or records or information . . . , Wrightway 18 Mechanical shall reimburse the Trust for all attorney’s fees and court costs and all audit fees 19 incurred . . . .” Id. ¶¶ 33, 39. 20 Under the terms of the Trust Agreement, “persons occupying positions akin to those of 21 corporate officers, like Steven Wright, are personally liable for contributions and related 22 damages owed to the Trust . . . .” Id. ¶ 64. 23

24 1 C. Plaintiff’s Allegations 2 In 2024, Plaintiff engaged a professional accounting firm to conduct a “payroll 3 compliance review”—i.e., an audit—of Wrightway Mechanical’s records for the period between 4 January 1, 2021, and March 31, 2024. Id. ¶ 41. On or about April 9, 2024, Plaintiff advised

5 Wrightway Mechanical that it was conducting the audit and requested that Wrightway 6 Mechanical provide records. Id. ¶¶ 42–43.

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Board of Trustees of the Employee Painters' Trust v. Wrightway Mechanical, LLC, an Idaho limited liability company, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/board-of-trustees-of-the-employee-painters-trust-v-wrightway-mechanical-wawd-2025.