Nicholas & Associates, Inc. v. Central Laborers’ Pension Fund

(1) Whether the Employee Retirement Income Security Act (ERISA) is the sole basis for determining liability for delinquent contributions to ERISA benefit funds; and (2) whether a state law may be used as an alternative enforcement mechanism to supplement the civil enforcement remedies in ERISA in order to recover ERISA benefit fund contributions from a party that is not liable for the contributions under ERISA.