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Fanning v. Wellman Dynamics Corporation
113 F. Supp. 3d 172
D.D.C.
2015
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Background

  • Fanning, as CEO and fiduciary of the Central Pension Fund (an ERISA multiemployer plan), sues Wellman Dynamics for unpaid employer contributions.
  • Central Pension Fund is maintained under its Restated Declaration of Trust and funded pursuant to a Collective Bargaining Agreement with IUOE Local 234.
  • Defendant agreed to pay certain contributions for hours worked under the Agreement.
  • Plaintiff filed the complaint on November 6, 2014; defendant was served but did not file a responsive pleading.
  • Clerk entered default against Wellman on December 4, 2014; plaintiff moved for default judgment under Rule 55(b)(2).
  • Court grants default judgment totaling $99,813.74, covering unpaid contributions, liquidated damages, interest, and attorney's fees.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Is a default judgment appropriate here? Default establishes liability for all well-pleaded allegations. Not advanced in the record. Yes; default judgment granted due to defendant's failure to respond.
Are damages properly calculated for unpaid contributions and related costs? Damages include unpaid contributions, liquidated damages, interest, and fees under 29 U.S.C. § 1132(g)(2). Not advanced in the record. Damages awarded totaling $99,813.74 with specified breakdown.
Is the awarded attorney's fees permissible under ERISA and the Trust? Fees and costs are authorized under 29 U.S.C. § 1132(g)(2)(D) and the Trust. Not advanced in the record. Attorney's fees and costs awarded as part of the default judgment.

Key Cases Cited

  • Jackson v. Beech, 636 F.2d 831 (D.C. Cir. 1980) (default judgment appropriate when adversarial process halted)
  • Adkins v. Teseo, 180 F.Supp.2d 15 (D.D.C. 2001) (liability established but damages require independent determination)
  • Flynn v. Mastro Masonry Contractors, 237 F.Supp.2d 66 (D.D.C. 2002) (damages may be based on detailed affidavits or documentary evidence)
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Case Details

Case Name: Fanning v. Wellman Dynamics Corporation
Court Name: District Court, District of Columbia
Date Published: Jul 6, 2015
Citation: 113 F. Supp. 3d 172
Docket Number: Civil Action No. 2014-1867
Court Abbreviation: D.D.C.