Ameris Bank v. 2 Sons Trucking LLC

Summary

The United States District Court for the Central District of California granted Ameris Bank's motion for default judgment against 2 Sons Trucking LLC and Willie Hall. The court found that the Eitel factors supported default judgment on claims for breach of an equipment financing agreement and guaranty. The court awarded $193,108.95 in compensatory damages, $14,071.40 in prejudgment interest, $7,462.17 in attorney fees, and $655.00 in costs.

Holdings

1. Default judgment was appropriate because all Eitel factors favored entry of judgment: plaintiff would otherwise lack a remedy, the claims were adequately pleaded, the amount sought was related to defendants' contractual misconduct, a factual dispute was unlikely, excusable neglect was unlikely after proper service, and defendants' failure to appear made a merits decision impractical.
2. Ameris Bank adequately pleaded that 2 Sons breached the equipment financing agreement and that Hall breached the guaranty.
3. Ameris Bank was entitled to $193,108.95 in compensatory damages for the remaining monthly payments due under the equipment financing agreement and guaranty.
4. Ameris Bank was entitled to prejudgment interest at 10 percent per annum from August 23, 2024, through May 15, 2025, totaling $14,071.40.
5. Ameris Bank was entitled to $7,462.17 in attorney fees and $655.00 in costs.

Questions Presented

1. Whether the Eitel factors favored entry of default judgment against defendants who were served but failed to appear.
2. Whether the complaint adequately pleaded breach-of-contract claims based on the equipment financing agreement and guaranty.
3. Whether the plaintiff proved compensatory damages, prejudgment interest, attorney fees, and costs recoverable on default judgment.

Disposition

other