The Laborers’ District Council Construction Industry Pension Fund, et al. v. Mossi Construction, Inc.

CourtDistrict Court, E.D. Pennsylvania
DecidedOctober 14, 2025
Docket2:25-cv-02008
StatusUnknown

This text of The Laborers’ District Council Construction Industry Pension Fund, et al. v. Mossi Construction, Inc. (The Laborers’ District Council Construction Industry Pension Fund, et al. v. Mossi Construction, Inc.) is published on Counsel Stack Legal Research, covering District Court, E.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
The Laborers’ District Council Construction Industry Pension Fund, et al. v. Mossi Construction, Inc., (E.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

THE LABORERS’ DISTRICT : COUNCIL CONSTRUCTION : INDUSTRY PENSION FUND, et al. : : CIVIL ACTION v. : No. 25-2008 : MOSSI CONSTRUCTION, INC. :

McHUGH, J. October 14, 2025 MEMORANDUM This is an ERISA action brought by several Laborers District Council Funds (“Plaintiff Funds”), the Laborers’ District Council of the Metropolitan Area of Philadelphia and Vicinity, and the General Building Contractors Association against Defendant Mossi Construction, Inc., seeking to enforce the terms of a collective bargaining agreement following Defendant’s failure to pay contributions.1 Following Mossi Construction’s failure to appear, the Clerk of Court entered default on October 3, 2025. See ECF 8. Plaintiffs move for an entry of default judgment pursuant to Federal Rule of Civil Procedure 55(b), supported by appropriate documentation and an affidavit from counsel. See Mot. for Default J., ECF 6. My review of the record confirms that Defendants were properly served with the Complaint and the pending motion but have failed to appear or respond within the time allowed. As such, default judgment will be entered against Defendant. I. Relevant Background Plaintiffs are the Laborers’ District Council Construction Industry Pension Fund; the Laborers’ District Council Heavy and Highway Health and Welfare Fund; the Laborers’ District

1 Jurisdiction exists pursuant to 29 U.S.C. §§ 185, 1132, and 1145. Council Education and Training Fund; the Laborers’ District Council Local, Regional, and State Health and Safety Benefit Fund; the Laborers’ District Council Prepaid Legal Fund; the Laborers’

District Council of the Metropolitan Area of Philadelphia and Vicinity, Laborers’ International Union of North America (“Union”); the Laborers’-Employers’ Cooperation and Education Trust; and the General Building Contractors Association. Mossi Construction is a Pennsylvania company that transacts business as a contractor or subcontractor in the construction industry, and as such is an “employer in an industry affecting commerce” as defined by ERISA. See 29 U.S.C. §§ 1002(5), (11), and (12). At all times relevant to this action, Mossi Construction was party to a Collective Bargaining Agreement (“CBA”) and Trust Agreements with the Union. See Compl. ¶¶ 14-15, ECF 1. The CBA requires Mossi Construction to make contributions to the Plaintiff Funds based upon hours worked by employees covered by the CBA. Id. ¶¶ 16, 31. Plaintiffs assert that, according to an audit, Mossi Construction

owes Plaintiff Funds $55,355.06 in unpaid contributions for the period between July 1, 2023 and May 31, 2025, in addition to accrued interest, audit costs, and attorney’s fees. Mot. for Default J. ¶¶ 9, 16, ECF 6; see also 29 U.S.C. § 1132(g)(2). As such, Plaintiffs filed suit seeking payment of unpaid employer contributions, accrued interest, audit costs, and attorney’s fees, and move for default judgment for an amount totaling $66,891.27, as well as leave to file a supplemental affidavit of additional attorney’s fees. Compl. ¶ 22; Mot. for Default J. ¶ 9. Defendant Mossi Construction has failed to appear or otherwise defend in this matter. Plaintiffs filed their Complaint against Mossi Construction on April 21, 2025. Compl. at 12; Mot. for Default J. ¶ 2. The summons and a copy of the Complaint were served on Mossi Construction

on April 22 and Mossi Construction executed a waiver of service on May 8, 2025. Mot. for Default J. ¶ 3; Waiver of Serv., ECF 5. Due to the waiver of service, Mossi Construction had until July 8

2 to respond to the Complaint. Mot. for Default J. ¶ 5. Mossi Construction did not respond to the Complaint or otherwise make an appearance. Plaintiffs filed a request for default, which the Clerk

of Court entered on October 3. See Req. for Default, ECF 7; Entry of Default by Mossi Construction, Inc., ECF 8. Plaintiffs filed this Motion for Entry of Default Judgment on August 8 and properly served Mossi Construction.2 See Certificate of Serv., ECF 6-3. Mossi Construction has not responded, appeared, or otherwise opposed the motion. II. Discussion Award of Default Judgment Rule 55(a) of the Federal Rules of Civil Procedure provides that “[w]hen a party against whom a judgment for affirmative relief is sought has failed to plead or otherwise defend, and that failure is shown by affidavit or otherwise, the clerk must enter the party’s default.” Following the entry of default, the clerk may enter a default judgment if the plaintiff’s claim is for a sum certain,

but otherwise the plaintiff must apply to the court for judgment. Fed. R. Civ. P. 55(b). It is within the court’s discretion whether to enter a default judgment. Hritz, 732 F.2d at 1180. In its exercise of discretion, the court must consider three factors as to whether a default judgment should be granted: “(1) prejudice to the plaintiff if default is denied, (2) whether the

2 It is generally accepted that, under Federal Rule of Civil Procedure 55, a party must be granted default before obtaining default judgment. See, e.g., Axalta Coating Sys., LLC v. SRS Ventures, Inc., No. CV 21- 03800, 2022 WL 874951, at *2 (E.D. Pa. Mar. 24, 2022) (McHugh, J.) (“Following the prerequisite entry of default, the decision to enter a default judgment is left to the court’s discretion.” (citing Hritz v. Woma Corp., 732 F.2d 1178, 1180 (3d Cir. 1984))); De Tore v. Jersey City Pub. Emps. Union, 511 F. Supp. 171, 176 (D.N.J. 1981): (“[N]o default judgment may be entered under either F.R.Civ.P. 55(b)(1) or (b)(2) unless a default has previously been entered by the clerk under 55(a). Thus, the entry of default is an essential predicate to any default judgment.”). Here, Plaintiffs mistakenly filed for default judgment prior to default, but because the Clerk of Court has granted default, I may now grant default judgment.

3 defendant appears to have a litigable defense, and (3) whether defendant’s delay is due to culpable conduct.” Chamberlain v. Giampapa, 210 F.3d 154, 164 (3d Cir. 2000).

Here, the analysis is more or less straightforward due to Mossi Construction’s lack of participation in the litigation, and consideration of the factors ultimately weighs in favor of granting a default judgment. First, there is a risk of prejudice to Plaintiffs if default judgment is denied, as Plaintiffs are owed tens of thousands of dollars under the terms of the CBA and Trust Agreements. Any further delay in adjudication will necessarily prejudice Plaintiffs’ right to the amount owed, particularly when there is not an inkling of indication that Mossi Construction intends to participate in this litigation. Second, it is unknown if the Defendant has any litigable defenses because Mossi Construction has not asserted any defense, either by answering the allegations of the Complaint or by opposing the present Motion for Default Judgment.

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The Laborers’ District Council Construction Industry Pension Fund, et al. v. Mossi Construction, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/the-laborers-district-council-construction-industry-pension-fund-et-al-paed-2025.