Aerotek, Inc. v. River Run Foods Inc

CourtDistrict Court, M.D. Pennsylvania
DecidedFebruary 4, 2025
Docket4:24-cv-00804
StatusUnknown

This text of Aerotek, Inc. v. River Run Foods Inc (Aerotek, Inc. v. River Run Foods Inc) is published on Counsel Stack Legal Research, covering District Court, M.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Aerotek, Inc. v. River Run Foods Inc, (M.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA

AEROTEK, INC., No. 4:24-CV-0804

Plaintiff, (Chief Judge Brann)

v.

RIVER RUN FOODS INC.,

Defendant.

MEMORANDUM OPINION

FEBRUARY 4, 2025 I. BACKGROUND This case was initially filed by Plaintiff, Aerotek, Inc. (“Aerotek”), against Defendant, River Run Foods, Inc. (“River Run Foods”), on May 14, 2024.1 For the past eight months, Defendant has failed to appear before this Court at all. Plaintiff moved for entry of default on September 10, 2024, and default was subsequently entered by the Clerk of Court.2 Then, Aerotek moved for default judgment on October 22, 2024.3 The Court ordered supplemental briefing on November 12, 2024 and provided Defendant with the opportunity to respond. River Run Foods refused to respond; therefore, the motion is now ripe for disposition. For the reasons that follow, the motion is granted.

1 Doc. 1 (Compl.). 2 Doc. 6 (Motion for Entry of Default); Doc. 7 (Clerk’s Entry of Default). II. DISCUSSION A. Default Judgment Standard

Federal Rule of Civil Procedure 55 allows the District Court to enter default judgment upon application by a party.4 “Generally, the entry of a default judgment is disfavored, and a court is required to exercise sound judicial discretion in deciding whether to enter default judgment.”5 “This element of discretion makes it clear that the

party making the request is not entitled to a default judgment as of right, even when defendant is technically in default and that fact has been noted under Rule 55(a).”6 It is “well settled that decisions relating to default judgments are committed to the sound discretion of the district court.”7

The Court must consider three factors in deciding whether to grant default judgment: “(1) prejudice to the plaintiff if default is denied, (2) whether the defendant appears to have a litigable defense, and (3) whether defendant’s delay is due to culpable conduct.”8 “But when a defendant has failed to appear or respond in any fashion to the complaint, this analysis is necessarily one-sided; entry of default judgment is typically

appropriate in such circumstances at least until the defendant comes forward with a

4 FED. R. CIV. P. 55(b)(2). 5 Kibbie v. BP/Citibank, No. 3:CV-08-1804, 2010 WL 2573845, at *2 (M.D. Pa. June 23, 2010). 6 10A Charles Alan Wright and Arthur R. Miller, FEDERAL PRACTICE AND PROCEDURE, § 2685 (Apr. 2020 Update). 7 Pesotski v. Summa & Lezzi, Inc., No. 1:17-cv-00221, 2017 WL 3310951, at *2 (M.D. Pa. Aug. 3, 2017) (Kane, J.). 8 Cahmberlain v. Giampapa, 210 F.3d 154, 164 (3d Cir. 2000). motion to set aside the default judgment under Rule 55(c).”9 In cases where a defendant fails to appear, this Court may enter default judgment “based solely on the fact that the

default has occurred.”10 The Court nevertheless considers those factors for the sake of completeness; in this case, they favor the grant of default judgment. First, Aerotek would be prejudiced by its “current inability to proceed with [its] action due to Defendant[‘s] failure to defend.”11 River Run Foods’ decision to not appear before this Court would prevent

Plaintiff from recovering any damages for its claim. Similarly, the second factor points in favor of the grant of default judgment. “Defendant has not responded to the allegations and, thereby, has failed to assert a defense.”12 Finally, there does not appear

to be any excuse for Defendant’s failure to appear or otherwise respond to Plaintiff’s complaint. Aerotek submitted the executed summons to the Court indicating that service occurred on June 27, 2024.13 Having received service, River Run Foods has yet to respond or appear in this action. Because Defendant has offered no explanation for its failure to engage in the litigation, the Court finds that River Run Foods is culpable.14

Therefore, default judgment is appropriate under these circumstances.

9 Deutsche Bank Nat. Trust Co. v. Strunz, No. 1:17-cv-00221, 2013 WL 122644, at *1 (M.D. Pa. Jan. 9, 2013) (Kane, J.). 10 Anchorage Assocs. v. Virgin Islands Bd. of Tax Rev., 922 F.2d 168, 177 n.9 (3d Cir. 1990). 11 Broad. Music, Inc. v. Kujo Long, LLC, No. 1:14-cv-00449, 2014 WL 4059711, at *2 (M.D. Pa. Aug. 14, 2014) (Kane, J.). 12 Pesotski, 2017 WL 3310951, at *2. 13 Doc. 5 (Executed Summons). 14 See Laborers Local Union 158 v. Shaffer, No. 1:CV-10-1524, 2011 WL 1397107, at *1 (M.D. Pa. Aug. 13, 2011) (Kane, J.). A finding that default judgment is warranted, however, “is not the end of the inquiry.”15 First, the Court must consider whether the “unchallenged facts constitute a

legitimate cause of action.”16 Although the defaulting party does not concede conclusions of law, “the factual allegations of the complaint, except those relating to the amount of damages, will be taken as true.”17 Plaintiff’s complaint asserts the following two claims against River Run Foods: breach of contract and unjust

enrichment. The Court now considers whether the allegations in the complaint, taken as true, state these claims. B. Facts Alleged in the Complaint On August 20, 2021, River Run Foods entered into an agreement with Aertoek to obtain staffing services (“the Services Agreement”).18 Aerotek “recruited contract

staff to work at [River Run Foods] sites under” Defendant’s “direction and supervision;” in exchange for these staffing services, River Run Foods agreed to pay Aerotek.19 Aerotek “submitted invoices and other proof of the work performed” to River Run Foods, with full payment due within fifteen days of receipt of an invoice.20

Aerotek continued to provide River Run Foods with services despite Defendant’s

15 Martin v. Nat’l Check Recovery Servs., LLC, No. 1:12-CV-1230, 2016 WL 3670849, at *1 (M.D. Pa. July 11, 2016) (Caldwell, J.). 16 Broad. Music, Inc. v. Spring Mount Area Bavarian Resort, Ltd., 555 F. Supp. 2d 537, 541 (E.D. Pa. 2008). 17 Comdyne I, Inc. v. Corbin, 908 F.2d 1142, 1149 (3d Cir. 1990). 18 Doc. 1 (Compl.) ¶ 9. 19 Id. ¶¶ 10-11. 20 Id. ¶¶ 13-14. failure to pay.21 Plaintiff has also made multiple demands on River Run Foods for payment of the outstanding balance.22

C. Causes of Action 1. Breach of Contract Under Pennsylvania law, a breach of contract claim “contain[s] three [elements]: ‘(1) the existence of a contract, including its essential terms, (2) a breach of a duty imposed by the contract[,] and (3) resultant damages.’”23 Here, the Complaint alleges

all three elements. The essential terms of payment have been properly alleged by incorporating the Services Agreement into the Complaint itself. Next, the Complaint alleges that River Run Foods has breached this agreement by failing to pay for the

services provided as documented through the attached invoices. Finally, damages have clearly resulted from this breach: the loss of payment. 2. Unjust Enrichment “A claim for unjust enrichment is ‘inapplicable when the relationship between the parties is founded on a written agreement or express contract.’”24 To plead unjust

enrichment in the alternative, “a dispute about the existence or validity of [the contract”

21 Id. ¶ 16. 22 Id. ¶ 18. 23 Udodi v. Stern, 438 F. Supp. 3d 293, 299 (E.D. Pa. 2020) (quoting Ware v. Rodale Press Inc., 322 F.3d 218, 225 (3d Cir. 2003)). 24 Holovich v. Progressive Specialty Ins.

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Aerotek, Inc. v. River Run Foods Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/aerotek-inc-v-river-run-foods-inc-pamd-2025.