Painters District Council No. 58 v. Kramer Drywall LLC
4:25-cv-00357
| E.D. Mo. | Jun 30, 2025Background
- Plaintiffs (Painters District Council No. 58 and related trusts) sued Kramer Drywall, LLC and its owner, Courtney Rhae Kramer, for failing to make contributions and provide required accountings to union employee benefit funds.
- The underlying claims arise under ERISA (29 U.S.C. §§ 1132, 1145) and the Labor Management Relations Act (29 U.S.C. § 185).
- Courtney Kramer executed a personal guaranty for the payments owed under the collective bargaining agreement.
- The Clerk entered default against Defendants when they did not respond to the complaint.
- Plaintiffs sought a default judgment for specified amounts owed (delinquent contributions, liquidated damages, interest, attorney fees and costs) and an order for Defendants to submit to a financial examination.
- The court reviewed affidavits and documentary evidence substantiating Plaintiffs' claimed amounts and ordered both monetary relief and compliance with future reporting requirements.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Entitlement to judgment by default | Defendants admitted all allegations | No response | Default is appropriate; facts deemed admitted |
| Amount of damages (delinquent contributions, etc) | Amounts are documented and accurate | No response | Court awards full requested relief, finds evidence sufficient |
| Order for financial examination/accounting | Needed to verify unknown liabilities | No response | Ordered—Defendants must submit to audit |
| Liability of Courtney Kramer as guarantor | Personally guaranteed company’s debts | No response | Liability imposed jointly and severally |
Key Cases Cited
- Marshall v. Baggett, 616 F.3d 849 (8th Cir. 2010) (well-pleaded factual allegations admitted by default)