United Site Services, Inc. v. Skyler Hadlock, Steed Metals Rock Springs, LLC, and Atlas Disposal of Utah, LLC

Summary

The United States District Court for the District of Utah granted United Site Services, Inc.'s renewed motion for default judgment against Skyler Hadlock. The court found sufficient evidentiary support for most claimed losses, including unauthorized charges and sales of company property, but rejected a $600 claim for an unauthorized trailer sale. The court entered judgment for $404,204.08, with post-judgment interest accruing at the statutory rate.

Holdings

1. The court had subject-matter jurisdiction under 28 U.S.C. § 1332(a) and personal jurisdiction over Hadlock.
2. After entry of default, a court may enter default judgment without a damages hearing when the amount claimed is a liquidated sum or is capable of mathematical calculation, but the requested damages must be supported by actual proof.
3. USS proved $404,204.08 in damages and was entitled to default judgment in that amount, but failed to prove the additional $600 claimed for the unauthorized trailer sale.

Questions Presented

1. Whether the court had subject-matter and personal jurisdiction to enter default judgment against Hadlock.
2. Whether USS established damages as a sum certain or an amount capable of mathematical calculation under Federal Rule of Civil Procedure 55(b).
3. Whether the evidence supported each of USS's six requested categories of damages.

Disposition

other