Christopher Santeiu v. Pergola Roof, LLC, et al.

Summary

The United States District Court for the Western District of North Carolina partially grants and partially denies Christopher Santeiu’s motion for default judgment against several Pergola defendants. The court enters judgment for $106,481.00 plus prejudgment and post-judgment interest based on the alleged breach of contract, but declines to enter judgment on the North Carolina Unfair and Deceptive Trade Practices Act claim because substantial aggravating circumstances were not sufficiently established. The case remains open for claims against the individual defendant and the remaining defendants.

Holdings

1. Default judgment may be entered when a defendant fails to plead or otherwise defend, but only when the well-pleaded factual allegations support the relief sought and service and personal jurisdiction are established.
2. A court may not enter default judgment against a defendant that was not properly served because proper service is necessary for personal jurisdiction.
3. The corporate defendants were liable on the pleaded breach-of-contract claim, and plaintiff was entitled to $106,481, prejudgment interest at the statutory rate from May 15, 2025 through judgment, and post-judgment interest under 28 U.S.C. § 1961.
4. The allegations that the corporate defendants were shell companies and never intended to fully perform, together with partial but inadequate performance, did not establish substantial aggravating circumstances beyond an alleged intentional breach of contract; therefore default judgment and attorney fees were denied on the UDTPA claim.
5. Damages are not admitted by default and must be independently determined by the court, although the court may rely on affidavits or documentary evidence without conducting an evidentiary hearing.

Questions Presented

1. Whether default judgment should be entered against the corporate defendants on the breach-of-contract claim.
2. Whether the pleadings established sufficient aggravating circumstances to support a North Carolina Unfair and Deceptive Trade Practices Act claim despite the defendants' default.
3. Whether plaintiff was entitled to contract damages, prejudgment interest, post-judgment interest, attorney fees, and costs.

Disposition

other