Plumber's Local 458 Holiday Vacation Fund v. Howard Immel, Inc
In Plumber's Local 458 Holiday Vacation Fund v. Howard Immel, Inc., 445 N.W.2d 43 (Wis. App. 1998), the Plaintiff laborers used their state's construction lien statute to collect a judgment against the property owner and general contractor. Id. at 44.
The court found against preemption arguing that its lien law was a "general statute without any specific reference to ERISA obligations [and that it provided] a remedy available against a certain class of creditors that transcends ERISA obligations and concerns." Id. at 46.