The Construction Industry Laborers Pension Fund and related benefit funds sought damages from Blue Moon Hauling LLC, a dissolved Missouri trucking company, for alleged violations of federal labor laws. The pension fund requested $91,469.20 in total damages, including unpaid contributions, interest, audit costs, and attorneys' fees for activity dating back to December 2023. Blue Moon Hauling never responded to the lawsuit after being served through the Missouri Secretary of State when its LLC registration was found to be dissolved.
Judge Phillips found that the pension fund overreached by seeking damages for a broader time period than originally alleged in their complaint. The court had previously entered default judgment ordering an accounting 'from April 1, 2024 onward' based on the amended complaint's allegations, but the fund's damage calculations included violations beginning in December 2023. As Phillips explained, 'Because the Court must rely on the facts as alleged in the Amended Complaint, and the Amended Complaint does not seek damages or plead violations of law prior to April 1, 2024, Plaintiffs cannot recover damages based on facts not pleaded in the Amended Complaint.'
The ruling underscores a fundamental principle in default judgment cases that even uncontested claims are bounded by the four corners of the complaint. Phillips noted that 'when a default judgment is entered, facts alleged in the complaint are taken as true,' citing Martinizing Int'l, LLC v. BC Cleaners, LLC, but emphasized that courts cannot award relief beyond what was properly pleaded.
The case began in September 2024 when the pension fund served Blue Moon Hauling through the Missouri Secretary of State after discovering the company's LLC registration had been dissolved. An amended complaint was filed in November and served in December, but the defendant never appeared. Default was entered in February 2025 at the direction of U.S. Magistrate Judge Jill A. Morris, and Phillips granted the default judgment motion in April 2025, ordering the defendant to permit an accounting for damages.
The pension fund had argued that its post-judgment audit revealed additional violations predating the April 2024 timeline alleged in the complaint, justifying the expanded damage period. However, Phillips rejected this approach, emphasizing that default defendants are still entitled to the protection of pleading requirements that limit the scope of potential liability to what was actually alleged against them.
The deferral highlights the challenges pension funds face in pursuing dissolved entities for benefit contribution violations, particularly when the procedural requirements of federal court limit recovery to specifically pleaded timeframes. Phillips' order suggests that even in default cases, plaintiffs cannot use post-judgment discovery to expand their damage theories beyond the original complaint's scope.
Phillips ordered the pension fund to submit revised damage calculations limited to the April 1, 2024 forward timeframe by April 24, 2026. The case illustrates the importance of comprehensive pleading in ERISA benefit fund collection actions, particularly when defendants may be defunct entities unable to contest expansive damage theories.