Greater St. Louis Construction Laborers Welfare Fund v. Aztec Construction Specialties, LLC

CourtDistrict Court, E.D. Missouri
DecidedJuly 31, 2023
Docket4:23-cv-00430
StatusUnknown

This text of Greater St. Louis Construction Laborers Welfare Fund v. Aztec Construction Specialties, LLC (Greater St. Louis Construction Laborers Welfare Fund v. Aztec Construction Specialties, LLC) is published on Counsel Stack Legal Research, covering District Court, E.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Greater St. Louis Construction Laborers Welfare Fund v. Aztec Construction Specialties, LLC, (E.D. Mo. 2023).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

GREATER ST. LOUIS CONSTRUCTION ) LABORERS WELFARE FUND, et al., ) ) Plaintiffs, ) ) v. ) Case No. 4:23-cv-430-MTS ) AZTEC CONSTRUCTION ) SPECIALTIES, LLC, ) ) Defendant. )

MEMORANDUM AND ORDER This matter is before the Court on Plaintiffs’ Motion for Default Judgment, Doc. [18]. For reasons discussed below, the Court grants in part and denies in part Plaintiffs’ Motion. * * * * * * * * * Plaintiffs bring this action against Defendant Aztec Construction Specialties, LLC pursuant to the Employee Retirement Income Security Act (“ERISA”), 29 U.S.C. § 1132(g) and § 1145. The nine Plaintiffs in this action are Greater St. Louis Construction Laborers Welfare Fund (the “Welfare Fund”), Construction Laborers Pension Trust of Greater St. Louis (the “Pension Fund”), St. Louis Vacation Fund (the “Vacation Fund”), Construction Laborers & Contractors Training Fund of Eastern Missouri (the “Training Fund”) (collectively, “the Funds”); the plan sponsors of each fund; and Local Unions Nos. 42 and 110 (the “Union”). Plaintiffs bring this to recover delinquent contributions owed to the Funds, which are employee benefit funds pursuant to ERISA. Specifically, Plaintiffs seek to recover delinquent contributions (plus interest), liquidated damages, attorneys’ fees, court costs, and accounting fees owed pursuant to the ERISA, 29 U.S.C. § 1132(g)(2). Doc. [1] ¶ 14. The Clerk of Court previously entered default against Defendant, consistent with Fed. R. Civ. P. 55(a). Doc. [16]. Plaintiffs now seek a default judgment. Doc. [28]. Defendant has not responded to either the entry of default or Plaintiffs’ Motion. I. LEGAL STANDARD “The Federal Rules of Civil Procedure commit the entry of a default judgment against a party to the sound discretion of the trial court.” Belcourt Pub. Sch. Dist. v. Davis, 786 F.3d 653, 661 (8th Cir. 2015) (quoting FTC v. Packers Brand Meats, Inc., 562 F.2d 9, 10 (8th Cir. 1977)) (per curiam). Once default has been entered against a defendant, “the allegations of the complaint, except as to the amount of damages[,] are taken as true.” Greater St. Louis Constr. Laborers Welfare Fund v.

Gateway Constr. Servs., 4:20-cv-808-SEP, 2020 WL 6483944, at *1 (E.D. Mo. Nov. 4, 2020) (quoting Greater St. Louis Constr. Laborers Welfare Fund v. AbatePro, Inc., 4:17-cv-2812-AGF, 2018 WL 5849980, at *1 (E.D. Mo. Sept. 6, 2018)). A court must then review the complaint and “consider whether the unchallenged facts constitute a legitimate cause of action, since a party in default does not admit mere conclusions of law.” Marshall v. Baggett, 616 F.3d 849, 852 (8th Cir. 2010) (citing Murray v. Lene, 595 F.3d 868, 871 (8th Cir. 2010)). Once the court determines the plaintiff stated a legitimate cause of action on a claim for an uncertain amount of damages, Federal Rule of Civil Procedure 55(b)(2) provides that “the court may conduct such hearings or order such references as it deems necessary and proper” in order to “enable the court to enter judgment.” Fed. R. Civ. P. 55(b)(2). “With respect to damages in an action for delinquent fringe benefits, pursuant

to 29 U.S.C. § 1132(g)(2), a plaintiff is entitled to recover all of the principal contributions owed, plus interest, liquidated damages . . . attorneys’ fees, and costs.” Gateway Constr. Servs., 2020 WL 6483944, at *2. II. DISCUSSION A. Defendant’s Liability At this stage, after the Clerk of Court has entered default against Defendant, the facts alleged in Plaintiffs’ Complaint are “deemed to be true.” See Everyday Learning Corp. v. Larson, 242 F.3d 815, 818 (8th Cir. 2001) (holding that when default judgment is entered on a claim for indefinite damages, facts alleged in the complaint are taken as true). Thus, the Court now considers whether the unchallenged facts in Plaintiffs’ Complaint constitute a “legitimate cause of action” against Defendant. Marshall, 616 F.3d at 852 (citing Murray, 595 F.3d at 871). Here, Plaintiffs seek to recover monetary damages under ERISA Section 502(g)(2), 29 U.S.C. § 1132(g)(2), for delinquent contributions in violation of ERISA Section 515, 29 U.S.C. § 1145. To

prove liability here, Plaintiffs must show Defendant is obligated, either under the terms of the plan or under the terms of a collective bargaining agreement (CBA), to make contributions. See 29 U.S.C. § 1145. Here, Plaintiffs allege Defendant is contractually obligated to remit contributions pursuant to the terms of two CBAs. Doc. [1] ¶ 8. While Plaintiffs allege Defendant is bound by the CBAs, the Court does not accept as true mere conclusions of law. Marshall, 616 F.3d at 852 (citing Murray v. Lene, 595 F.3d 868, 871 (8th Cir. 2010)). In support of their Motion for Default Judgment, Plaintiffs present two CBAs as evidence that Defendant was obligated to make contributions. See Docs. [19-3] & [19-4]. On April 30, 2018, Defendant became signatory, Doc. [19-2], to a 2014–2019 Collective Bargaining Agreement (“the CBA”) between Local Union Nos. 42, 53, and 110 and the Site Improvement Association (“SITE”),

Doc. [19-3]. The CBA was effective through February 28, 2019. Doc. [19-3]. SITE and some of the Unions negotiated a successor CBA (“Successor CBA”) effective from March 1, 2019, through February 29, 2024. Doc. [19-4]. On February 8, 2021, Defendant executed a Notice of Acceptance of the Successor CBA. Doc. [19-5]. The Court finds Defendant is liable for delinquent contributions from April 30, 2018, to February 28, 2019, see Docs. [19-2] & [19-3], and from February 8, 2021, to the date of the last requested delinquent contributions, see Docs. [19-5] & [19-4]. However, the Court finds Plaintiffs have not shown whether Defendant is liable for unpaid contributions from the period of February 28, 2019, to February 8, 2021.1 Put another way, Plaintiffs have not shown Defendant is contractually obligated to make contributions for a nearly two-year period in question. In conclusion, Plaintiffs have stated a legitimate cause of action against Defendant, for the purposes of default judgment, during two periods of time: (1) April 30, 2018, to February 28, 2019, and (2) February 8, 2021, to the date of the last requested delinquent contributions. For these two periods, the Court requests that Plaintiffs provide the Court with a subtotal, with supporting

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Related

Marshall v. Baggett
616 F.3d 849 (Eighth Circuit, 2010)
Murray v. Lene
595 F.3d 868 (Eighth Circuit, 2010)
Fort Yates Public School Dist. v. Jamie Murphy
786 F.3d 653 (Eighth Circuit, 2015)

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Greater St. Louis Construction Laborers Welfare Fund v. Aztec Construction Specialties, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/greater-st-louis-construction-laborers-welfare-fund-v-aztec-construction-moed-2023.