Smith v. Jedlicki
- Katherine Menendez
- 0:23-cv-01273
- U.S. District Court · District of Minnesota
- 10
In Smith v. Jedlicki, Judge Menendez granted default judgment and an injunction, requiring records and leaving damages to be calculated later.
The trustees and labor benefit funds may obtain records, delinquent contributions, interest, liquidated damages, attorney’s fees, and collection costs from Garrett Jedlicki and G. F. Jedlicki, Inc., subject to the later calculation and court order.
What happened
In Smith v. Jedlicki, trustees of several labor benefit funds sought judgment against Garrett Jedlicki and G. F. Jedlicki, Inc. after the defendants did not respond to the lawsuit. The claims involved unpaid contributions, required records, and related amounts under collective bargaining agreements and the Employee Retirement Income Security Act.
The agreements required the defendants to make monthly contributions, report them accurately, and provide payroll and employment records for an audit covering January 1, 2020, through December 31, 2021. The defendants did not provide the records, answer the complaint, or participate in the case.
Judge Katherine Menendez granted the motion for default judgment and injunction. She ordered the defendants to provide the records and ruled that they were liable for delinquent contributions, interest, and liquidated damages, but the final money judgment and attorney-fee award will be determined after further submissions.
The detailed version
- Smith v. Jedlicki · No. 0:23-cv-01273
- Katherine Menendez
- Apr. 16, 2024
Background
Joel Smith and Heather Grazzini, or their successors as trustees, sued Garrett Jedlicki doing business as G.F. Jedlicki and G. F. Jedlicki, Inc. The plaintiffs are trustees of several labor benefit funds. The opinion states that the funds are administered under the Employee Retirement Income Security Act (ERISA).
The defendants were bound by collective bargaining agreements requiring them to make monthly fringe-benefit contributions for covered employees, accurately report the contributions, and provide payroll and employment records for audits. The funds requested records for January 1, 2020, through December 31, 2021. The defendants did not provide those records, preventing the funds from calculating the unpaid contributions, interest, and liquidated damages.
The plaintiffs filed the complaint on May 8, 2023. The defendants were served but did not answer or otherwise respond. The clerk entered default on June 15, 2023. The defendants also did not appear at the February 15, 2024 hearing on the plaintiffs’ motion for default judgment and injunction.
Court’s Analysis
A default judgment is a judgment entered after a properly served defendant fails to defend the case. The court explained that, after default, the factual allegations are generally accepted as true, except allegations about the amount of damages. The court must still determine whether those facts support a valid legal claim.
The court found that the uncontested allegations established that the defendants entered agreements requiring contributions, accurate reporting, and disclosure of employment records. It concluded that the defendants breached those agreements and granted default judgment regarding damages arising from the breach. The court also found the defendants liable for delinquent contributions, interest, and liquidated damages, although the amount remained to be calculated.
Attorney’s Fees and Injunction
The court allowed the plaintiffs 21 days to submit a request for attorney’s fees with supporting information. The defendants may oppose that request within 14 days after it is served. The court stated that it will issue a final order and enter judgment after resolving the fee issue.
The court also granted the request for an injunction. The defendants were ordered to submit their contribution reports or payroll books and records for the audit period. After the plaintiffs file a motion identifying the amount they determine is owed for delinquent contributions, liquidated damages, interest, reasonable attorney’s fees, and collection costs, the defendants may respond within 21 days. The court will then decide whether to enter the money judgment; no hearing will be held unless the court orders one.
Disposition
Judge Katherine Menendez granted the plaintiffs’ Motion for Default Judgment and Injunction. Default judgment will be entered in due course against G. F. Jedlicki, Inc. and Garrett Jedlicki for damages arising from the breach of the collective bargaining agreements, plus attorney’s fees incurred in the litigation. The order did not state a final dollar amount.
Read the full 10-page opinion on CourtListener, the free public archive maintained by the Free Law Project.