Keith Tappe v. Instrulink LLC, et al.

Summary

The United States District Court for the District of Arizona granted Keith Tappe’s motion for default judgment against Instrulink LLC, William Robert Doenges, and Judith Ann Doenges in an unpaid-wages action. The court awarded $2,925 against Instrulink LLC, with $1,587.60 of that amount imposed jointly and severally against all three defendants under Arizona wage laws.

Holdings

1. Default judgment is appropriate because the Eitel factors, considered together, favor entry of judgment.
2. The complaint contained sufficient factual allegations, accepted as true for purposes of default judgment, to state claims under federal and Arizona wage law.
3. The requested $2,925 in trebled unpaid regular wages was proportional to the harm and did not weigh against default judgment.
4. Instrulink LLC was liable for $2,925 in trebled unpaid wages, and Instrulink LLC, William Robert Doenges, and Judith Ann Doenges were jointly and severally liable for $1,587.60 in trebled Arizona minimum wages.

Questions Presented

1. Whether default judgment should be entered under the seven Eitel factors.
2. Whether the complaint sufficiently stated federal and Arizona wage claims for purposes of default judgment.
3. What amount of damages should be awarded and which defendants are liable for those damages under the Arizona Minimum Wage Act and Arizona Wage Act.

Disposition

other