Board of Trustees Sheet Metal Workers’ National Pension Fund v. Gentlemen Sheet Metal Ltd.

CourtDistrict Court, E.D. Virginia
DecidedOctober 27, 2025
Docket1:25-cv-00803
StatusUnknown

This text of Board of Trustees Sheet Metal Workers’ National Pension Fund v. Gentlemen Sheet Metal Ltd. (Board of Trustees Sheet Metal Workers’ National Pension Fund v. Gentlemen Sheet Metal Ltd.) is published on Counsel Stack Legal Research, covering District Court, E.D. Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Board of Trustees Sheet Metal Workers’ National Pension Fund v. Gentlemen Sheet Metal Ltd., (E.D. Va. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Alexandria Division ) BOARD OF TRUSTEES SHEET METAL ) WORKERS’ NATIONAL PENSION FUND, ) ) Plaintiff, ) ) v. ) Civil Action No. 1:25-cv-803-MSN-WEF ) GENTLEMEN SHEET METAL LTD., ) ) Defendant. ) ) REPORT AND RECOMMENDATION Plaintiff, the Board of Trustees of the Sheet Metal Workers’ National Pension Fund (“NPF” or “Fund”), initiated this action pursuant to the Employee Retirement Income Security Act of 1974 (“ERISA”) against Defendant Gentlemen Sheet Metal Ltd. (“GSM”) for unpaid withdrawal liability,1 liquidated damages, interest, and attorneys’ fees and costs. This matter is presently before the Court on Plaintiff’s Motion for Default Judgment. Dkt. 7.2 Pursuant to 28 U.S.C. § 636(b)(1)(C), the undersigned United States Magistrate Judge has reviewed the Motion and relevant pleadings and is filing with the Court these proposed findings of fact and recommendations. A copy of this Report and Recommendation will be provided to all interested parties. 1 Withdrawal liability refers to the financial liability of an employer as a result of its early withdrawl from an employee pension benefit plan. See 29 U.S.C. § 1399. 2 The relevant filings before the Court include Plaintiff’s Complaint (“Compl.”) (Dkt. 1); Plaintiff’s Motion for Default Judgment (“Mot. Default J.”) (Dkt. 7); Brief in Support of Plaintiff’s Motion for Default Judgment (“Mem. Supp.”) (Dkt. 8); Declaration of Debra Elkins Santi (“Santi Decl.”) (Dkt. 8-1); Declaration of Diana M. Bardes (“Bardes Decl.”) (Dkt. 8-2); and For the reasons set forth below, the undersigned recommends that the Court enter an order GRANTING Plaintiff’s Motion for Default Judgment against Defendant GSM and entering judgment against Defendant in the amount of $2,876,337.64, consisting of Defendant’s withdrawal liability in the amount of $2,155,662.12, liquidated damages in the amount of $431,132.42, and accrued interest on the withdrawal liability at the rate provided under the plan which is 0.0205% compounded daily and which results in $289,543.10 of accrued interest through August 31, 2025.3

The undersigned further recommends that the Court award Plaintiff $4,735.81 in attorneys’ fees and costs as well as post-judgment interest on the award of attorneys’ fees and costs. I. PROCEDURAL AND FACTUAL BACKGROUND On May 9, 2025, Plaintiff NPF filed this lawsuit against GSM pursuant to Sections 502(a)(3), (d)(1), (g)(2), 515, 4219, 4221, and 4301 of ERISA, 29 U.S.C. §§ 1132(a)(3), (d)(1), (g)(2), 1145, 1399, 1401, and 1451. Compl. ¶ 1. In essence, Plaintiff alleges that Defendant is liable due to its early withdrawal from the Fund in violation of its contractual and statutory obligations. Defendant was properly served with the summons, Complaint, and related materials on June 25, 2025, in accordance with Rules 4(c) and (h) of the Federal Rules of Civil Procedure

(“Fed. R. Civ. P.”). Dkt. 4. However, Defendant failed to appear or respond by July 16, 2025, as required by Fed. R. Civ. P. 12(a)(1)(A)(i). As a result, on July 24, 2025, Plaintiff requested entry of default against Defendant (Dkt. 5), and on July 28, 2025, the Clerk of Court entered default pursuant to Fed. R. Civ. P. 55(a) ( Dkt. 6). Plaintiff filed the instant Motion, accompanying memorandum, declarations, supporting documentation, and notice of hearing on July 29, 2025. Dkts. 7–9. Defendant failed to appear for the hearing on the instant Motion before the undersigned on August 29, 2025, and the Court took

3 Interest on withdrawal liability is governed by 29 U.S.C. § 1132 (g)(2)(B) and § 1399(c)(5). As discussed below, interest on the withdrawal liability will continue to accrue the matter under advisement to issue this Report and Recommendation. Dkt. 11. II. SERVICE OF PROCESS, JURISDICTION, AND VENUE 1. Service of Process Before a court can render default judgment, it must be satisfied that the defaulting party has been properly served. Under Fed. R. Civ. P. 4(h), a corporation may be served “by delivering a copy of the summons and of the complaint to an officer, a managing or general agent, or any other

agent authorized by appointment or by law to receive service of process and—if the agent is one authorized by statute and the statute so requires—by also mailing a copy of each to the defendant.” On June 25, 2025, Plaintiff’s process server served Defendant by providing the summons, Complaint, and related materials to Paul Appel, President of GSM. Dkt. 4. Therefore, service of process was properly affected upon an officer or a managing or general agent designated by law to accept service of process on behalf of GSM. Id.; Mem. Supp. at 5. Accordingly, the undersigned finds that Defendant was properly served in compliance with the Federal Rules of Civil Procedure. 2. Jurisdiction and Venue Before entering default judgment against Defendant, the Court must have (1) subject-matter

jurisdiction over the claims, (2) personal jurisdiction over Defendant, and (3) venue must be proper in this judicial district. First, the undersigned finds that this Court has proper subject-matter jurisdiction. A federal district court has specifically been granted subject-matter jurisdiction over ERISA actions pursuant to 29 U.S.C. Sections 1132(e), 1132(f), and 1451(c). In addition, jurisdiction is proper under 28 U.S.C. § 1331, which grants federal courts original jurisdiction over all civil actions “arising under the Constitution, laws, or treaties of the United States.” Here, Plaintiff asserts claims under ERISA, which is a federal statute. Compl. ¶ 1. Accordingly, this action arises under the laws of the United States. Second, the undersigned finds that this Court has personal jurisdiction over Defendant. Under ERISA’s nationwide service of process provision, personal jurisdiction is proper where a defendant has been validly served and maintains sufficient contacts with the United States such that the exercise of jurisdiction is consistent with the Fifth Amendment of the United States Constitution. See 29 U.S.C. § 1132(e)(2); Trs. of the Plumbers & Pipefitters Nat’l Pension Fund v. Plumbing Servs., Inc., 791 F.3d 436, 443–44 (4th Cir. 2015)(citation omitted)(“Where a

defendant has been validly served pursuant to a federal statute’s nationwide service of process provision, a district court has personal jurisdiction over the defendant so long as jurisdiction comports with the Fifth Amendment.”); see also Bd. of Trs., Sheet Metal Workers’ Nat’l Pension Fund v. McD Metals, Inc., 964 F. Supp. 1040, 1045 (E.D. Va. 1997).

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Board of Trustees Sheet Metal Workers’ National Pension Fund v. Gentlemen Sheet Metal Ltd., Counsel Stack Legal Research, https://law.counselstack.com/opinion/board-of-trustees-sheet-metal-workers-national-pension-fund-v-gentlemen-vaed-2025.