Stellantis Financial Services, Inc. v. Michael Winding

Summary

The United States District Court for the Northern District of California granted Stellantis Financial Services, Inc.’s motion for default judgment against Michael Winding. The court found that it had subject-matter and personal jurisdiction, that service was proper, and that the Eitel factors supported default judgment on Stellantis’s breach-of-guaranty claim. The court awarded $481,865.64 in damages, including prejudgment interest, and granted leave to seek additional attorney’s fees and costs.

Holdings

1. The Court had diversity jurisdiction because Stellantis was a Texas citizen, Winding was established to be a California citizen for diversity purposes, and the amount in controversy exceeded $75,000.
2. The Court had personal jurisdiction over Winding because the guaranty contained his consent to jurisdiction in the federal and state courts of the state in which he resides, and the claims arose from the guaranty.
3. Service was proper because Stellantis personally served an individual named Michael Winding in Missouri City, Texas, and supplemental evidence showed that the served individual was almost certainly the defendant.
4. The Eitel factors supported entry of default judgment against Winding.
5. Stellantis established its breach-of-guaranty claim and was entitled to recover $468,621.99 in breach-of-contract damages plus $13,243.65 in prejudgment interest.

Questions Presented

1. Whether the Court had subject-matter jurisdiction based on complete diversity and the amount in controversy.
2. Whether the Court had personal jurisdiction over Winding under the guaranty's consent-to-jurisdiction provision.
3. Whether service of process on an individual named Michael Winding in Missouri City, Texas was adequate.
4. Whether the Eitel factors supported entry of default judgment.
5. Whether Stellantis proved entitlement to breach-of-guaranty damages and prejudgment interest.

Disposition

other