International Painters and Allied Trades Industry Pension Fund v. Temp-Tech Industries, Inc.

District Court, D. Maryland·Decided June 20, 2025·No. 1:25-cv-00056·Unknown

Opinion

. IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND

INTERNATIONAL PAINTERS AND ALLIED TRADES INDUSTRY PENSION □ FUND, et al., . kg Plaintiffs, □□ oe v. * CIVIL NO. JKB-25-0056 TEMP-TECH INDUSTRIES, INC., Defendant. * * & * * * * * * * * *

MEMORANDUM Plaintiffs International Painters and-Allied Trades Industry Pension Fund and Daniel Williams brought suit against Defendant Temp-Tech Industries, Inc. (ECF No. 1.) The Court previously granted Plaintiffs’ Motion for Default Judgment with respect to Defendant’s liability but directed additional briefing with respect to damages and fees. (ECF No. 12.) The Court will now enter judgment in favor of Plaintiffs in the amount of $453,049.34 in damages and $3,308 in attorneys’ fees and costs. i. Background ,

The factual and procedural background this case is laid out in detail in the Court’s prior Memorandum and Order. (See ECF No. 12 at 1-2.) The Court concluded that Defendant was liable under 29 U.S.C. § 1381, explaining that: As alleged in the Complaint, Defendant was required to contribute to the Fund, a multiemployer plan, and withdrew from it. Plaintiffs then sent a demand letter to the Defendant, notifying it of its withdrawal liability and the date it was due. Defendant did not make the requisite payment, and Plaintiffs sent a cure letter. Defendant did not make any payments, nor did it seek review or initiate arbitration. This is sufficient to state a claim.

. 1 , .

Ud. at 5.) The Court directed Plaintiffs to file additional briefing with respect to damages. (/d. at 8-9.) Standard

After entry of default under Federal Rule of Civil Procedure 55(a), a party may move for default judgment. Entry of default does not alone entitle a plaintiff to judgment: □ “The defendant, by [its] default, admits the plaintiff's well-pleaded allegations of fact... [but] is not held... to admit conclusions of law. In short, . . . a default is not treated as an absolute confession by the defendant of [its] liability and of the _ plaintiffs right to recover.” The court must .. . determine whether the [conceded facts] support the relief sought in [the] action. Ryan v. Homecomings Fin. Network, 253 F.3d 778, 780 (4th Cir. 2001) (quoting Nishimatsu Constr. Co. y. Houston Nat’! Bank, 515 F.2d 1200, 1206 (Sth Cir. 1975)). Further, while a plaintiff's factual allegations are deemed admitted, allegations relating to the amount of damages are not deemed admitted based on a defendant's failure to respond toa suit. Meade Communities, LIC v. Whitaker, Civ. No. ELH-22-2381, 2023 WL 2914787, at *2 (D. Md. Apr. 11, 2023). Instead: the Court must make an independent determination regarding allegations as to damages. In so doing, the court may conduct an evidentiary hearing. However, the court may also make a determination of damages without a hearing, so long as there is an adequate evidentiary basis in the record to support an award of the requested damages. Id *3. . = Analysis As the Court previously explained, in an action such as this one, where judgment is awarded in favor of the plan, “the court shall award the plan” the following: (A) the unpaid contributions, oe (B) interest on the unpaid contributions, (C) an amount equal to the greater of — (i) interest on the unpaid contributions, or

□□ (it) liquidated damages provided for under the plan in an amount not in excess of 20 percent (or such higher percentage as may be . permitted under Federal or State law) of the amount determined by the court under subparagraph (A), - (D) reasonable attorney’s fees and costs of the action, to be paid by the defendant, and (E) such other legal or equitable relief as the court deems appropriate. 29 U.S.C. § 1132(g)(2) (emphasis added). Thus, Plaintiffs are entitled to an award of each of the above-listed categories of damages and fees. A. Damages The Court previously concluded that Plaintiffs are entitled to: (1) the outstanding □

withdrawal liability in the amount of $358,280 and (2) liquidated damages of $71,656. (ECF No.

12 at 6-8.) Thus, the accompanying judgment will award Plaintiffs these amounts. The Court also previously concluded that Plaintiffs are entitled to interest beginning on April 22, 2024. (See ECF No. 12 at 6-7.) Plaintiffs previously suggested that the interest was $28,031.73 through April 1, 2025. (Id. at 7.) However, as the Court explained, Plaintiffs had not

_ sufficiently identified the appropriate interest rate used or how they arrived at that figure. □□□□ ‘Plaintiffs have provided both a supplemental figure and an explanation of how they arrived at that figure. (See ECF No. 14 at 2; ECF No. 14-1.) Plaintiffs now explain that the total interest, through May 20, 2025, is $21,974.51, and that interest will continue to accrue at a rate of $39.27 per day. (ECF No. 14 at 2.)' Plaintiffs provide a Declaration explaining how they arrived at those figures. (ECF No. 14-1.) The Court concludes that Plaintiffs are entitled to $21,974.51 plus $1,138.83

(which represents the daily interest of $39.27 multiplied by 29 days since May 20, 2025), for a total of $23,113.34. Thus, the accompanying Judgment will award Plaintiffs that amount.

| This lower figure reflects why the Court sought additional information from the Plaintiffs regarding their calculation of interest. Plaintiffs are cautioned to be more precise in the future. 3 oe

.B. Attorneys’ Fees and Costs

_ The Court also previously concluded that Plaintiffs are entitled to an award of reasonable attorneys’ fees and costs. (ECF No. 12 at 8.) Plaintiffs earlier sought fees and expenses totaling $11,566.89. (See id.) In its prior Memorandum and Order, the Court explained that Fourth Circuit precedent provided that “ERISA attorney’s fees [are] categorically unavailable for expenses incurred while exhausting’ administrative remedies.” (/d. (quoting Rego v. Westvaco Corp., 319 F.3d 140, 150 (4th Cir. 2003). “And while “district courts have not applied Rego’s limitation □□ fee awards in ERISA cases in a way. to exclude all pre-litigation fees and costs,’ certain prelitigation work may not appropriately fall within the scope of a fee award under 29 U.S.C. $.1132(g).” Gd. (quoting Int'l Painters & Allied Trades Indus. Fund v. Interiors by Steve, Inc., - Civ. No. JRR-21-229, 2023 WL 4446572, at *8—-9 (D. Md. July 11, 2023).) Further, the Court

- explained that: This action was filed on January 8, 2025, and the invoices reflect work dating back to May 2023. (See ECF No. 11-8 at 1.) Most of the fees were incurred in 2023 and ‘2024, and relate to the demand and cure letters. (See ECF No. 11-8 at 1-16.) Only the entries from July 2, 2024 forward appear to relate to this litigation. (See, e.g., ECF No. 11-8 at 17 (entry from July 2, 2024: “research and analyze controlled group members for purposes of naming them in complaint); id at 18 (entry from August 13, 2024: “prepare complaint against employer for interim payment”).) Plaintiffs have not addressed this issue in their briefing, and will be directed to explain why all of the requested fees are recoverable, or to revise their fee request.

_ In light ofthis direction from the Court, rather than explain why the previously sought amount was recoverable, Plaintiffs have revised their fee request and now seek $3,308. (ECF No.

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International Painters and Allied Trades Industry Pension Fund v. Temp-Tech Industries, Inc., (D. Md. 2025).

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