Board of Trustees, Sheet Metal Workers' National Pension Fund, v. Elite Erectors, Inc., 212 F.3d 1031 (7^th Cir. 2000)-Several pension funds sued Elite Erectors, and two alleged "alter ego" entities, for failure to contribute to the fund and other trusts pursuant to a collective bargaining agreement.  The district court entered judgment, holding all three defendants jointly and severally liable for the $18,000 debt.  When the funds initiated collection proceedings, the two alleged "alter ego" entities, Skylight Consultants of America, Inc. and one Mary Lowry, residents of Indiana, filed a motion under Fed. R. Civ. P. 60(b)(4), asking the district judge in Indiana to declare the Virginia judgment void because, they asserted, the Eastern District of Virginia lacked personal jurisdiction over them.

            The district court judge in Indiana mistakenly concluded that personal jurisdiction could be established in Virginia only if Skylight and Lowry were Elite's alter egos, as the Funds' complaint asserted.  This court pointed out that 29 U.S.C. § 1132(e)(2) provides nationwide service to bring "a defendant" into the action, not just those persons liable under ERISA—a  "step that would conflate jurisdiction with the merits."  Furthermore, this court found that in federal litigation, and in ERISA in particular, it is not necessary, as Skylight and Lowry contend, that plaintiffs must allege each element of a cause of action.  Even if the court could dismiss the Funds' complaint under Fed. R. Civ. P. 12(b)(6), the shortcomings in proving alter ego status would not have affected the district court's subject-matter jurisdiction.  Because the Virginia district court had jurisdiction, the Indiana district court must enforce the judgment.