Montana Retail Store Employees Health and Welfare Plan v. C&S Jones Group LLC
2:23-cv-01342
W.D. Wash.Mar 11, 2025Background
- Plaintiffs, including the Montana Retail Store Employees Health and Welfare Plan, are seeking unpaid employee benefit contributions from Defendant C&S Jones Group LLC under ERISA.
- C&S Jones entered a collective bargaining agreement (CBA) requiring monthly contributions to the Trust for covered employees.
- A payroll audit from January 1, 2018, to May 31, 2022, found $60,621.98 in unpaid contributions, with additional liquidated damages and interest.
- C&S Jones failed to respond to the audit, pay the delinquent sums, or appear in the litigation despite proper service.
- Plaintiffs moved for default judgment after the court entered default due to defendant’s lack of response; total amount sought was $104,386.97 including attorneys' fees and costs.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether default judgment should be granted | No response from C&S; Eitel factors favor default | None | Default judgment granted for Plaintiffs |
| Entitlement to unpaid contributions and related sums | ERISA & CBA require these payments | None | Plaintiffs entitled to all requested amounts |
| Reasonableness and support of damages sought | Damages calculations are clear, supported by documentation | None | Amount sought is proportional, evidence sufficient |
| Jurisdiction (subject matter and personal) | ERISA grants jurisdiction; service proper | None | Court has jurisdiction over claims and party |
Key Cases Cited
- Aldabe v. Aldabe, 616 F.2d 1089 (9th Cir. 1980) (outlining discretion for entry of default judgment)
- Eitel v. McCool, 782 F.2d 1470 (9th Cir. 1986) (establishing seven factors for default judgment)
- TeleVideo Sys., Inc. v. Heidenthal, 826 F.2d 915 (9th Cir. 1987) (well-pleaded facts are taken as true on default)
- Geddes v. United Fin. Grp., 559 F.2d 557 (9th Cir. 1977) (requiring damages to be proved even by defaulted party)
- Cripps v. Life Ins. Co. of N. America, 980 F.2d 1261 (9th Cir. 1992) (supporting ERISA jurisdiction and sufficiency of default pleadings)
