Ameris Bank v. M & T Transport LLC

Summary

The United States District Court for the Central District of California granted Ameris Bank’s motion for default judgment against M & T Transport LLC and Ryan McKeegan. The court found that defendants breached an equipment financing agreement and a corresponding personal guaranty. Judgment awarded compensatory damages, prejudgment interest, attorney fees, and costs.

Holdings

1. Default judgment was warranted because all Eitel factors favored entry of judgment: plaintiff would otherwise lack a remedy, the claims were well pleaded, the requested amount was proportionate to defendants' conduct, material-fact disputes were unlikely, excusable neglect was unlikely, and defendants' failure to appear made a merits determination impracticable.
2. Plaintiff adequately pleaded that M & T breached the equipment financing agreement and that McKeegan breached the personal guaranty.
3. The court could award $270,281.76 in compensatory damages without conducting a damages hearing because the amount was ascertainable from the agreements, accounting records, and supporting declaration.
4. Plaintiff was entitled to $34,354.56 in prejudgment interest at 10 percent per annum from July 11, 2024, through May 19, 2025.
5. Plaintiff was entitled to $9,005.63 in attorney fees under the contractual fee provision and C.D. Cal. Local Rule 55-3, and $561.00 in taxable costs under Federal Rule of Civil Procedure 54(d)(1) and applicable local rules.

Questions Presented

1. Whether the Eitel factors supported entry of default judgment against defendants who were served but failed to appear.
2. Whether plaintiff adequately pleaded breach-of-contract claims based on the equipment financing agreement and personal guaranty.
3. Whether plaintiff proved the amount of compensatory damages without a damages hearing.
4. Whether plaintiff was entitled to prejudgment interest, attorney fees, and costs.

Disposition

other