BASF Corporation v. Dougan

CourtDistrict Court, E.D. California
DecidedMarch 24, 2025
Docket1:24-cv-01115
StatusUnknown

This text of BASF Corporation v. Dougan (BASF Corporation v. Dougan) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
BASF Corporation v. Dougan, (E.D. Cal. 2025).

Opinion

1 2 3 4 5 UNITED STATES DISTRICT COURT 6 EASTERN DISTRICT OF CALIFORNIA 7 8 BASF CORPORATION, Case No. 1:24-cv-01115-JLT-CDB

9 Plaintiff, FINDINGS AND RECOMMENDATION TO GRANT BASF CORPORATION’S MOTION 10 v. FOR DEFAULT JUDGMENT AS TO BREACH OF CONTRACT CLAIMS ONLY 11 ISA S. DOUGAN, et al., (Docs. 14, 19) 12 Defendants. 14-DAY DEADLINE 13

14 15 Pending before the Court is the motion of Plaintiff BASF Corporation (“Plaintiff”) for 16 default judgment against Defendants Isa S. Dougan, individually, and doing business as United 17 Collision (collectively, “Defendants”), filed on January 3, 2025 (Doc. 14), with an amended 18 motion filed on March 12, 2025 (Doc. 19). No Defendants filed an opposition to the motion and 19 the time to do so has expired. On March 13, 2025, the Court convened for hearing on the 20 motion. (Doc. 21). Attorney Edward Martinovich appeared on behalf of Plaintiff via Zoom 21 videoconference and no other party appeared. (Id.). 22 Background 23 Plaintiff initiated this action with the filing of a complaint on September 19, 2024, 24 asserting causes of action for breach of contract, unjust enrichment, and declaratory relief. (Doc. 25 1). Plaintiff alleges that, on or about November 20, 2017, the parties entered into a contract (the 26 “contract” or “Requirements Agreement”) requiring Defendants to fulfill all of its “[r]efinish 27 products” up to a minimum purchase requirement of $729,000.00 from Plaintiff. As 1 certain equipment available to Defendant, in the value of $18,910.95. (Id. at 3). Upon breach or 2 termination of the contract, the equipment was to be returned to Plaintiff within 30 days. 3 Separately, if Defendants breached or terminated the contract prior to satisfying the minimum 4 purchase amount of $729,000.00, Defendants were required to refund the $200,000.00 5 consideration sum, according to the following schedule: “(i) one-half of the amount of the 6 Contract Fulfillment Consideration, plus (ii) one-half of the amount of the Contract Fulfillment 7 Consideration multiplied by the percentage of the Minimum Purchases requirement outstanding.” 8 (Id. at 4). 9 Plaintiff alleges that, in June 2023, Defendant breached the contract by ceasing to 10 purchase refinish products from Plaintiff and, instead, began purchasing them from a competitor 11 prior to meeting the minimum purchase amount. As of the date of breach, Defendants had 12 purchased a total of $146,560.87 in product. (Id. at 4-5). Plaintiff alleges that Defendants refused 13 to refund $180,000.00 in consideration, comprising half of the total amount of $200,000 (namely, 14 $100,000) plus half of the amount of consideration multiplied by the percentage of the minimum 15 purchase amount outstanding (namely, $100,000 multiplied by 80%, or $80,000), thus totaling 16 $180,000.00. (Id. at 5). 17 Plaintiff further alleges that Defendants failed to return the equipment, or pay the value 18 thereof to Plaintiff, and breached the personal guaranty clause of the contract by failing to pay 19 $180,000 in consideration, plus $582,439.13 for the balance outstanding of the minimum 20 purchase amount. Plaintiff alleges that, on October 13, 2023, a notice was sent to Defendants 21 explaining they were in default of contractual obligations, demanding return of the consideration 22 sum due and return of, or payment for, the equipment. (Id.). Plaintiff attaches to the complaint 23 the contract at issue (Doc. 1-1) and the notice sent to Defendants (Doc. 1-2). 24 After executed summonses were filed reflecting service upon Defendants (Docs. 5, 6), 25 Defendants failed to respond or otherwise make an appearance in this action. Upon request by 26 Plaintiff (Doc. 7), the Clerk of the Court entered default as to Defendants (Doc. 8). Plaintiff filed 27 a motion for default judgment on January 3, 2025. (Doc. 14). 1 states in its notice of motion that it is entitled to return of the $200,000 contract consideration 2 sum. (Id. at 2). In the accompanying memorandum of points and authorities, it states the sum to 3 be returned as $180,000 at first (Doc. 14-1 at 4), setting forth a formula for this number; this is 4 also the consideration sum stated in the complaint (Doc. 1 at 6). Later in the memorandum when 5 discussing the Eitel factors, Plaintiff asserts entitlement to $200,000 in contract consideration 6 (Doc. 14-1 at 8-9). Plaintiff requests a total amount of $783,365.13 at the end of the 7 memorandum of points and authorities (id. at 11), as opposed to the $781,349.98 sought in the 8 complaint (Doc. 1 at 7). In the declaration of Christopher Banuelos accompanying Plaintiff’s 9 motion for default judgment, Plaintiff references $180,000 in consideration that Defendant 10 refused to pay, as well as a total amount of $781,349.98 (the same amount as in the complaint). 11 (Doc. 14-3 at 3). Additionally, Plaintiff’s motion states Michigan substantive law governs 12 BASF’s breach of contract claims. (Doc. 14-1 at 6). 13 The Court convened for hearing on Plaintiff’s motion for default judgment on February 14 10, 2025. (Doc. 15). During the hearing, the Court questioned counsel for Plaintiff as to the 15 above sums and the basis for Plaintiff’s requested damages, as well as the relevance of Michigan 16 law to the claims at issue. The Court also noted that no proof of service had been filed indicating 17 service of the motion for default judgment upon Defendants. Thus, the Court ordered Plaintiff to 18 complete service and file proof thereof. Upon filing of said proof (Doc. 16), the Court scheduled 19 a continued hearing regarding the motion on March 13, 2025. (Doc. 17). 20 Prior to this hearing, Plaintiff filed an amended motion for default judgment. (Doc. 19). 21 In the amended motion, Plaintiff clarified that seeks only $180,000.00 in damages, representing 22 the contract consideration sum, as well as $926.00 in costs. (Id. at 2-3). In addition, Plaintiff 23 attaches a second declaration of Christopher Banuelos, stating that the “North America 24 Automotive Coatings Refinish business” maintains a primary place of business at 26701 25 Telegraph Road, Southfield, Michigan. (Doc. 19-2 at 2). 26 Legal Standard 27 In general, “default judgments are ordinarily disfavored,” as “[c]ases should be decided 1 616 (9th Cir. 2016) (quoting Eitel v. McCool, 782 F.2d 1470, 1472 (9th Cir. 1986)). Prior to 2 entry of default judgment, there must be an entry of default. See Fed. R. Civ. P. 55. Upon entry 3 of default, the factual allegations of the complaint, save for those concerning damages, are 4 deemed to have been admitted by the defaulting party. Fed. R. Civ. P. 8(b)(6); see Geddes v. 5 United Fin. Grp., 559 F.2d 557, 560 (9th Cir. 1977) (per curiam). However, “a defendant is not 6 held to admit facts that are not well-pleaded or to admit conclusions of law.” United States v. 7 Cathcart, No. C 07-4762-PJH, 2010 WL 1048829, at *4 (N.D. Cal. Feb. 12, 2010) (citing 8 Nishimatsu Constr. Co. v. Houston Nat’l Bank, 515 F.2d 1200, 1206 (5th Cir.1975)); accord 9 DirecTV, Inc. v. Hoa Huynh, 503 F.3d 847, 854 (9th Cir. 2007) (allegations that do no more than 10 “parrot” the elements of a claim not deemed admitted). In other words, “facts which are not 11 established by the pleadings of the prevailing party, or claims which are not well-pleaded, are not 12 binding and cannot support the judgment.” Danning v.

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BASF Corporation v. Dougan, Counsel Stack Legal Research, https://law.counselstack.com/opinion/basf-corporation-v-dougan-caed-2025.