OSF Healthcare System an Illinios not for profit corporation d/b/a Saint Francis Medical Center v. Star Transport, Inc. Health Care Plan Exact Name Unknown, 1:15-cv-01436

OSF Healthcare provided medical services to an insured under Star Transport’s employee health plan and sought reimbursement for unpaid bills.
OSF sued the plan and Star Transport on October 23, 2015 under ERISA § 502(a)(1)(B) for $192,195.78 (assigned benefits), plus attorney’s fees and costs.
Defendants were served on November 12, 2015, failed to answer, and the clerk entered default; a prior default-judgment motion was stayed due to bankruptcy and later renewed.
OSF also alleged a claim under ERISA § 502(c)(1)(B) against Star for failure to produce plan documents, seeking statutory penalties for each day of noncompliance.
The court treated OSF’s monetary requests as joint and several against the plan and Star for the reimbursement and fees/costs, and separately awarded a § 1132(c) penalty against Star as plan administrator.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Liability under ERISA § 502(a)(1)(B) for unpaid benefits	OSF: plan owes $192,195.78 as assigned beneficiary	Plan/Star: no response / default	Default taken as admission; judgment entered for $192,195.78 jointly and severally
Award of attorney's fees and costs under ERISA § 502(g)	OSF: seeks $4,295 fees and $492.50 costs incurred litigating claim	Defendants: no response / default	Fees $4,295 and costs $492.50 awarded jointly and severally
§ 502(c)(1)(B) statutory penalty for failure to produce plan documents	OSF: requested daily statutory penalty for delayed response to document request beginning Sept 14, 2014	Star: no response / default	Penalty awarded against Star; court calculated entitlement for 817 days but granted OSF's requested $67,400
Whether judgment can be entered against corporate/plan defendants when plan identity/control unclear	OSF: may name entities that control the plan; seeks relief against plan and Star	Defendants: no response / default	Court construes claims as against plan and entities controlling it and enters joint and several judgment (citing authority allowing such practice)

e360 Insight v. The Spamhaus Project, 500 F.3d 594 (7th Cir.) (personal jurisdiction requirement before default judgment)
Dundee Cement Co. v. Howard Pipe & Concrete Prod., Inc., 722 F.2d 1319 (7th Cir.) (well-pleaded allegations taken as true upon default)
Breuer Elec. Mfg. Co. v. Toronado Sys. of Am., Inc., 687 F.2d 182 (7th Cir.) (default judgment establishes liability on pleaded causes of action)
Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101 (U.S.) (ERISA authorizes suits against fiduciaries and administrators to enforce plan compliance)
Larson v. United Healthcare Ins. Co., 723 F.3d 905 (7th Cir.) (plaintiff may sue entities that control or are effectively the plan when plan identity is unclear)
Leister v. Dovetail, Inc., 546 F.3d 875 (7th Cir.) (permitting suit against entities when the plan is not unambiguously identified)