Trustees of the Sheet Metal Workers' Local Union No. 28 Funds and Plans v. Five…

Background

The trustees of several related funds and the International Association of Sheet Metal, Air, Rail, and Transportation Workers’ Local Union No. 28, AFL-CIO, sued Five Star Kitchen Installations, Inc. The plaintiffs sought damages for unpaid fringe-benefit contributions allegedly required by the Employee Retirement Income Security Act, the Labor Management Relations Act, and a collective bargaining agreement.

The court had already granted the plaintiffs’ motion for default judgment on January 7, 2020. Because the defendant had not appeared to contest liability, the court referred the remaining issues—damages, attorneys’ fees, costs, and interest—to Magistrate Judge Figueredo for an inquest, meaning a proceeding to determine the amount owed.

Report and Recommendation

On October 17, 2022, Magistrate Judge Figueredo recommended awarding the plaintiffs $376,801.76 in principal damages for delinquent fringe-benefit contributions, $66,895.23 in prejudgment interest, $75,360.35 in liquidated damages, $10,050 in attorneys’ fees, and $768.41 in costs. The parties did not file objections. Because there were no objections, the District Court reviewed the recommendation for clear error, which means an obvious mistake rather than simply a different view of the evidence.

Ruling

Judge Daniels found no error—clear or otherwise—in the magistrate judge’s analysis and adopted the recommended judgment in full. The court ordered Five Star Kitchen Installations, Inc. to pay the plaintiffs the listed amounts: $376,801.76 in compensatory damages, $66,895.23 in prejudgment interest, $75,360.35 in liquidated damages, $10,050 in attorneys’ fees, and $768.41 in costs. The Clerk of Court was directed to close the action.