I.A.M. National Pension Fund v. Km Entertainment Consultants

District Court, District of Columbia·Decided November 14, 2025·No. Civil Action No. 2025-0146·Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

I.A.M. NATIONAL PENSION FUND, et al.,

Plaintiffs,

Civil Action No. 25 - 146 (SLS)

v. Judge Sparkle L. Sooknanan

KM ENTERTAINMENT CONSULTANTS,

Defendant.

MEMORANDUM OPINION

In this lawsuit, I.A.M. National Pension Fund and its Executive Director Yolanda Montgomery seek to recover unpaid contributions under the Employment Retirement Income Security Act of 1974. They move for default judgment against KM Entertainment Consultants (KMEC), seeking a monetary award of $215,454.77 and injunctive relief directing KMEC to submit to an audit of its payroll and wage records. For the reasons explained below, the Court grants I.A.M.’s motion.

BACKGROUND

A. Factual Background The Court draws the facts, accepted as true, from the Plaintiffs’ “pleadings, motion for default judgment, and various attachments.” Omni Bridgeway Ltd. v. Ministry of Infrastructure & Energy of the Republic of Albania, 23-cv-1938, 2025 WL 506570, at *1 (D.D.C. Feb. 14, 2025).

I.A.M. is a multiemployer pension benefit plan organized under the Employee Retirement Income Security Act (ERISA). Compl. ¶¶ 6–7, ECF No. 1. Ms. Montgomery is the Fund’s Executive Director and its fiduciary. Compl. ¶ 8. Employers who sign collective bargaining

agreements (CBAs) with the International Association of Machinists and Aerospace Workers (the Union) are bound to the Fund’s Trust Agreement and must make pension contributions to the Fund for all eligible employees. See Compl. ¶¶ 13–15. KMEC is such an employer. Compl. ¶ 12.

Under its CBA with the Union, KMEC must make contributions to the Fund “no later than ‘the twentieth (20th) day of the month following the month for which the Contributions are being paid.’” Compl. ¶ 16. If KMEC fails to make required contributions, it may be held “liable for liquidated damages of 20% of the amount due” and must pay “simple interest . . . on all amounts due at the rate of 18% per annum from the date of the delinquency until the due date payment is received.” Compl. ¶ 15.

In addition to contributions, KMEC must submit monthly “remittance reports.” Compl.

¶ 25. These reports enable the Fund to record the hours worked by each plan participant so that their benefit accrual and vesting can be properly calculated. Compl. ¶ 27. The reports also allow the Fund to verify that KMEC has paid any contributions that it owes. Compl. ¶ 23. If KMEC fails to submit timely remittance reports, its contributions for a month “shall be deemed to be unpaid” and the Fund may “take steps to conduct a payroll audit.” Compl. ¶¶ 28–29.

The Plaintiffs allege that KMEC has failed to make monthly contributions to the Fund or submit remittance reports since April 2022. Compl. ¶¶ 18, 26. At the time it filed the instant motion, I.A.M. estimated that KMEC owed $140,308.96 in unpaid contributions. Young Decl. ¶ 8, ECF No. 7-1.

B. Procedural Background I.A.M. filed this lawsuit on January 17, 2025. ECF No. 1. The docket reflects that I.A.M.

properly served KMEC on May 2, 2025. ECF No. 3. On June 11, 2025, I.A.M. moved for entry of default, ECF No. 4, and on June 13, 2025, the Clerk of the Court entered default, ECF No. 6.

I.A.M. filed a motion for default judgment on July 28, 2025. Mot. for Default J., ECF No. 7. KMEC has not responded to the motion or otherwise appeared in this lawsuit in any way.

LEGAL STANDARD

Federal Rule of Civil Procedure 55 provides that courts may enter default judgments to “safeguard plaintiffs when the adversary process has been halted because of an essentially unresponsive party.” Mwani v. bin Laden, 417 F.3d 1, 7 (D.C. Cir. 2005) (cleaned up). “The determination of whether default judgment is appropriate is committed to the discretion of the trial court.” Int’l Painters & Allied Trades Indus. Pension Fund v. Auxier Drywall, LLC, 531 F. Supp. 2d 56, 57 (D.D.C. 2008) (citing Jackson v. Beech, 636 F.2d 831, 835 (D.C. Cir. 1980)).

A default judgment is appropriate when a defendant may be considered “totally unresponsive,” and “its default plainly willful” as reflected by a “failure to respond to the summons and complaint, the entry of a default, and the motion for a default judgment.” Bricklayers & Trowel Trades Int’l Pension Fund v. Civitillo Masonry, Inc., No. 23-cv-2598, 2025 WL 358757, at *2 (D.D.C. Jan. 31, 2025) (cleaned up). While a defaulting defendant is “deemed to admit every well- pleaded allegation in the complaint,” the court must confirm the allegations are well-pled and must make an “independent determination of the sum to be awarded unless the amount of damages is certain.” Id. (cleaned up).

DISCUSSION

The Court concludes that I.A.M.’s Complaint alleges sufficient facts to establish KMEC’s liability and that I.A.M. is entitled to monetary and injunctive relief. Accordingly, for the reasons explained below, the Court grants I.A.M.’s motion for default judgment.

A. Jurisdiction Even when a defendant has not answered the plaintiff’s complaint, a court still has an “‘affirmative obligation’ to ensure that it has subject matter jurisdiction over the suit.”

Redes Andinas de Comunicaciones S.R.L. v. Republic of Peru, No. 22-cv-3631, 2024 WL 4286107, at *2 (D.D.C. Sept. 24, 2024) (quoting James Madison Ltd. by Hecht v. Ludwig, 82 F.3d 1085, 1092 (D.C. Cir. 1996)).

A court must also “satisfy itself that it has personal jurisdiction before entering judgment against an absent defendant.” Mwani, 417 F.3d at 6. In the case of a default judgment, the plaintiff need only raise a prima facie case of personal jurisdiction. See id. at 7. To assess personal jurisdiction over a non-resident defendant, courts in this District conduct “a two-part inquiry” that asks (1) whether jurisdiction is proper under the District of Columbia’s long-arm statute and (2) whether the exercise of personal jurisdiction comports with the constitutional requirements of due process. Buholtz v. Sogamoso, No. 17-cv-1766, 2019 WL 13225374, at *1 (D.D.C. Jan. 10, 2019). Section 13-423(a)(1) of D.C.’s long-arm statute allows courts to exercise personal jurisdiction over out of state individuals based on their “transacting any business in the District of Columbia,” and the D.C. Circuit has said that this requirement is “coextensive with the Constitution’s due process limit.” First Chicago Int’l v. United Exch. Co., 836 F.2d 1375, 1377 (D.C. Cir. 1988) (quoting D.C. Code § 13-423(a)(1)). This means the Court may exercise specific jurisdiction if “there is a sufficient relationship between the gravamen of the complaint . . . and the District of Columbia, such that the maintenance of the suit does not offend traditional notions of fair play and substantial justice.” McLaughlin v. Hartford Life & Annuity Ins. Co., 299 F. Supp. 3d 115, 118 (D.D.C. 2017) (cleaned up). ERISA further provides that actions like this one may be brought in the district “where the plan is administered . . . and process may be served in any other district where a defendant resides or may be found.” 28 U.S.C. § 1132(e)(2).

Here, the Court is satisfied that it has subject matter jurisdiction based on ERISA’s express grant of exclusive jurisdiction to United States district courts for claims like the one at issue. See

29 U.S.C. § 1132(e)(1). The Court is also satisfied that I.A.M. has stated a prima facie case for personal jurisdiction. Its allegations support that KMEC’s business relationship with the D.C.- based Fund makes it amenable to suit here without offending traditional notions of fair play and substantial justice.

Free access — add to your briefcase to read the full text and ask questions with AI

I.A.M. National Pension Fund v. Km Entertainment Consultants, (D.D.C. 2025).

I.A.M. National Pension Fund v. Km Entertainment Consultants (I.A.M. National Pension Fund v. Km Entertainment Consultants) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related