M & K Employee Solutions, Inc. v. Trustees of IAM National Pension Fund

On May 21, 2026, a U.S. federal court addressed a dispute between M & K Employee Solutions, Inc. and the Trustees of the IAM National Pension Fund. The pension fund trustees alleged that M & K Employee Solutions incurred withdrawal liability under ERISA after ceasing contributions to the multiemployer plan. The trustees argued that the company either directly withdrew from the plan or was part of a controlled group of businesses designed to evade pension obligations. M & K contested the assessment, challenging the fund's calculation of liability and the application of controlled group rules. The case turned on statutory interpretation of ERISA's withdrawal liability provisions and factual findings regarding corporate relationships and business transactions.

The court ruled in favor of the Trustees of the IAM National Pension Fund, holding that M & K Employee Solutions, Inc. was subject to withdrawal liability and responsible for the assessed payments.

Whether M & K Employee Solutions, Inc. was liable for withdrawal payments under ERISA, and whether controlled group or evasive transaction rules applied to attribute the pension fund's claim to the company.

The decision reinforced the enforcement of multiemployer pension withdrawal liability, cautioning employers against corporate restructuring aimed at avoiding ERISA obligations. It provided guidance on controlled group liability and strengthened the ability of pension funds to collect delinquent employer contributions.