Jonathan Padilla v. Hugo Diaz, et al.

Padilla · United States District Court for the Southern District of Indiana · February 27, 2026 · No. 4:23-cv-00170-SEB-KMB

Summary

The United States District Court for the Southern District of Indiana denies Plaintiff Jonathan Padilla's motion for default judgment against Hugo Diaz because the complaint does not adequately support personal liability or veil piercing. The court grants default judgment as to liability against Huge Music Group, LLC on breach of contract and account stated claims, while denying recovery under unjust enrichment because an express contract governs. The court refers the matter for an evidentiary hearing to determine damages.

Holdings

  1. Default judgment against Diaz was denied because the complaint did not allege facts sufficient to pierce the corporate veil or otherwise establish that Diaz was personally liable for the LLCs' debts.
  2. The well-pleaded allegations established Huge Music Group's liability for breach of contract, and default judgment was granted as to liability on Count III.
  3. The allegations established a prima facie account-stated claim against Huge Music Group, and default judgment was granted as to liability on Count II.
  4. Padilla was not entitled to recover against Huge Music Group under unjust enrichment because the parties' rights were controlled by an express contract.
  5. A final damages award could not be entered on the submitted materials because the requested amounts were not supported by definite figures or adequately detailed calculations; an evidentiary hearing was required.

Questions Presented

  1. Whether default judgment should be entered against Hugo Diaz personally based on the alleged agreements and a corporate-veil-piercing theory.
  2. Whether the well-pleaded allegations established Huge Music Group's liability for breach of contract.
  3. Whether the allegations established Huge Music Group's liability on an account-stated theory.
  4. Whether Padilla could recover against Huge Music Group under unjust enrichment in addition to breach of contract.
  5. Whether the evidence established damages with sufficient certainty to support a final default judgment without an evidentiary hearing.

Disposition

other

Cases Cited (20)

  • VLM Food Trading Int'l, Inc. v. Ill. Trading Co., 811 F.3d 247, 255 (7th Cir. 2016)(followed)
  • Dundee Cement Co. v. Howard Pipe & Concrete Prods., Inc., 722 F.2d 1319, 1323 (7th Cir. 1983)(followed)
  • WaterFurnace Int'l, Inc. v. B&S Sheet Metal Mechanical, Inc., No. 1:15-CV-008 JD, 2015 WL 6510446, at *3 (N.D. Ind. Oct. 28, 2015)(followed)
  • Meridian N. Invs. LP v. Sondhi, 26 N.E.3d 1000, 1004 (Ind. 2015)(followed)
  • Pazmino v. Bose McKinney & Evans, LLP, 989 N.E.2d 784, 786 (Ind. Ct. App. 2013)(followed)
  • Smith v. Isaacs, 777 S.W.2d 912, 913 (Ky. 1989)(followed)
  • Morgan v. O'Neil, 652 S.W.2d 83, 85 (Ky. 1983)(followed)
  • Escobedo v. BHM Health Assocs., Inc., 818 N.E.2d 930, 934-35 (Ind. 2004)(followed)
  • Inter-Tel Techs., Inc. v. Linn Station Properties, LLC, 360 S.W.3d 152, 165 (Ky. 2012)(followed)
  • Delange v. Curbow, No. 2:06-CV-379-PPS-APR, 2010 WL 1936202, at *3 (N.D. Ind. May 12, 2010)(followed)

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