Puget Sound Electrical Workers Health & Welfare Trust Fund v. Merit Co.

Plaintiffs, a group of benefit trust funds, appeal the summary judgment dismissal of their claims to collect unpaid employer contributions owed to them by an insolvent subcontractor. The trial court found that Wash ington’s public works lien statutes, which provide a mechanism for collection of a defaulting subcontractor’s obligations from the general contractor, are preempted by the Federal Employee Retirement Income Security Act of 1974 (ERISA), as amended, 29 U.S.C. § 1001 et seq. We agree and affirm the judgments below.

I

The facts relevant to this appeal are not in dispute. The plaintiffs…