ITPE Pension Fund v. Stronghold Security, LLC.
23 F. Supp. 3d 1
D.D.C.2014Background
- Plaintiffs are fiduciaries of the ITPE Pension Fund seeking delinquent contributions from Stronghold Security, LLC under ERISA and the Pension Fund’s Trust Agreement; complaint filed January 8, 2013.
- Default was entered against Stronghold on April 25, 2013; plaintiffs moved for default judgment without opposition; evidentiary hearing occurred August 16, 2013.
- Fund is a multi-employer ERISA plan under LMRA terms; contributing employers owe $0.80 per hour with reporting for hours worked; delinquency triggers liquidated damages and interest.
- Plaintiffs seek relief including unpaid contributions, interest, liquidated damages, attorney’s fees, potential audit, and injunctive relief; updated calculations filed after hearing.
- Magistrate Judge Robinson recommended granting the motion; District Judge Jackson adopted the recommendation on February 7, 2014, entering judgment consistent with the recommendation.
- Judgment amounts include delinquent contributions, late payments, estimated future amounts, interest, liquidated damages, attorney’s fees, and post-judgment relief/injunction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether default judgment is proper under ERISA § 1132(g)(2). | Stronghold’s liability for unpaid contributions, interest, and liquidated damages is established by the default. | Stronghold would contest extent of damages or noncompliance with procedural requirements. | Default judgment proper; damages independently calculated under § 1132(g)(2). |
| Whether the requested an injunctive relief including an audit is warranted. | Equitable relief is appropriate due to ongoing noncompliance. | Defendant disputes need for audit or injunctive relief. | Injunctive relief granted; audit and cooperation with Fund permitted. |
| Whether the amounts awarded are supported by the record. | Evidence and updated declarations support the listed totals for contributions, interest, liquidated damages, and fees. | Not asserted; not opposed due to default. | Court independently determines sums to be awarded consistent with record and § 1132(g)(2). |
Key Cases Cited
- Boland v. Elite Terrazzo Flooring, Inc., 763 F.Supp.2d 64 (D.D.C.2011) (default judgment standard; independent damages calculation required)