Michael R. Ward v. Amazon.com Services LLC

Summary

The United States District Court for the Western District of Washington grants Amazon.com Services LLC's motion under Federal Rule of Civil Procedure 55(c) to set aside the Clerk's entry of default. The Court finds that Amazon's failure to respond was inadvertent rather than culpable, that Amazon presented potentially meritorious defenses, and that setting aside default would not prejudice Ward. Ward's motion for default judgment and request for fees are denied, and Amazon's answer is treated as validly filed as of October 15, 2025.

Holdings

1. Amazon established good cause because its failure to respond was negligent and inadvertent rather than intentional or in bad faith, it presented facts that could constitute defenses, and Ward failed to show cognizable prejudice beyond delay and the need to litigate on the merits.
2. Amazon's failure to timely respond was not culpable because the record showed carelessness and negligence, not an intentional, devious, willful, or bad-faith failure to respond.
3. Amazon satisfied the meritorious-defense requirement by alleging facts that, if true, would constitute defenses, including legitimate non-discriminatory and non-retaliatory reasons for its actions and a binding arbitration agreement.
4. Setting aside the entry of default would not prejudice Ward because his asserted expenditure of time and the need to litigate on the merits did not constitute tangible prejudice.
5. Ward was not entitled to fees, costs, or compensation for his time because Amazon's conduct was not prolonged or egregious and did not resemble the conduct warranting sanctions in Nilsson.

Questions Presented

1. Whether Amazon established good cause under Federal Rule of Civil Procedure 55(c) to set aside the Clerk's entry of default.
2. Whether Amazon presented a meritorious defense to Ward's employment-related claims.
3. Whether setting aside the entry of default would prejudice Ward.
4. Whether Ward was entitled to fees or other compensation as a condition of setting aside default.

Disposition

other