Groden v. N&D Transportation Co., Inc., No. 15-2553 (1st Cir. 2017)Annotate this Case
The district court erred in refusing to vacate its dismissal of a pension fund’s lawsuit against an employer’s alleged alter egos. In the lawsuit, the fund sought $1.2 million in unpaid withdrawal liability that was previously assessed against the employer in a default judgment. The district court dismissed the case, concluding that subject matter jurisdiction did not exist under the Employee Retirement Income Security Act (ERISA). The court subsequently denied Appellant’s motion for post-judgment relief. The First Circuit vacated the court’s post-judgment ruling and remanded the case for further proceedings, holding that the fund’s alter ego claims were anchored in ERISA, and thus the fund had established federal subject matter jurisdiction.