Terry Maupin; Erik Maupin v. Shawn J. Morris

Summary

The United States District Court for the District of Hawaii adopted a magistrate judge’s findings and recommendation granting in part and denying in part the plaintiffs’ motion for default judgment against Shawn J. Morris. The court awarded plaintiffs $1 in nominal damages for breach of contract, denied relief on their implied-warranty and unfair-trade-practices claims, denied attorneys’ fees, and rejected their objections. The court ordered entry of judgment and closure of the case.

Holdings

1. Plaintiffs were entitled only to $1 in nominal damages because they failed to prove the amount and legal basis of their claimed contract damages with admissible evidence and reasonable certainty.
2. Plaintiffs were not entitled to a second evidentiary hearing or an opportunity to supplement the record after failing to submit admissible evidence at the hearing on their default-judgment motion.
3. Plaintiffs did not qualify as consumers entitled to bring a claim under Haw. Rev. Stat. § 480-2 because the condominium was used primarily as a business rental property rather than for personal, family, or household purposes.
4. Plaintiffs were not entitled to attorneys' fees because an award would not be reasonable where their only successful claim resulted in $1 in nominal damages.

Questions Presented

1. Whether plaintiffs established entitlement to more than nominal damages on their defaulted breach-of-contract claim.
2. Whether plaintiffs were entitled to an additional evidentiary hearing to supplement their proof of damages.
3. Whether plaintiffs qualified as consumers entitled to bring a claim under Haw. Rev. Stat. § 480-2 for alleged unfair and deceptive trade practices involving a condominium used as a rental property.
4. Whether plaintiffs were entitled to attorneys' fees after receiving only $1 in nominal damages.

Disposition

other