St. Joseph Health Center, LLC, and St. Joseph Operating Company, LLC v. Cedar Holdings, LLC

Summary

The United States District Court for the Southern District of West Virginia granted the plaintiffs’ motion for costs and attorney fees under Federal Rule of Civil Procedure 4(d)(2), awarding $1,175.00. The court also granted default judgment and confirmed a JAMS arbitration award totaling $500,000 in damages and $106,442.15 in attorney fees and costs, along with applicable interest. The action was dismissed from the court’s docket after entry of judgment.

Holdings

1. Because Defendant failed without good cause to sign and return the requested waiver of service, Plaintiffs were entitled to recover the $195 process-server cost and $980 in attorney fees, totaling $1,175.00.
2. Default judgment was appropriate because Defendant failed to appear or defend, the complaint and supporting documentation established the amount due, and Defendant was not a minor or incompetent person.
3. The court confirmed the September 22, 2024 JAMS Final Arbitration Award pursuant to the Federal Arbitration Act and entered judgment requiring Defendant to pay the awarded damages, fees, costs, and interest.

Questions Presented

1. Whether Defendant's failure without good cause to sign and return Plaintiffs' requested waiver of service required an award of service costs and reasonable attorney fees under Federal Rule of Civil Procedure 4(d)(2).
2. Whether default judgment was appropriate where Defendant failed to appear or defend the action.
3. Whether the court should confirm the final arbitration award under the Federal Arbitration Act.

Disposition

dismissed