Brough Trucking LLC v. Truck Doctor Inc

District Court, W.D. Oklahoma·Decided June 2, 2025·No. 5:24-cv-00412·Unknown

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF OKLAHOMA

BROUGH TRUCKING LLC, ) ) Plaintiff, ) ) v. ) Case No. CIV-24-412-R ) TRUCK DOCTOR, INC., an Oklahoma ) Corporation, and John Does 1-5, ) ) Defendants. ) ORDER

Before the Court is Plaintiff’s Supplemental Motion on Damages and Attorney Fees and Costs [Doc. No. 30]. The Court previously granted Plaintiff’s motion seeking entry of default judgment as a sanction against Defendant Truck Doctor, Inc. and reserved ruling on the amount of damages to permit Plaintiff to provide additional information in support of its damages request. Plaintiff has now provided its additional information and, after considering the evidence and argument presented, the Court awards damages as outlined below. This action concerns Defendant’s failure to properly perform repair work on Plaintiff’s truck. The Complaint alleges that Plaintiff is the owner of a long-hail tractor, the tractor was brought to Defendant Truck Doctor because the engine was overheating, and Defendant determined that the engine needed an in-frame overhaul and repair. Defendant then sold the repair work without obtaining approval for all fees that were charged. Although Defendant represented that they repaired the engine, the truck broke down several weeks later and the engine had to be replaced. The Complaint asserts claims for violation of the Oklahoma Consumer Protection Act, 15 O.S., §752, et seq., negligence, breach of contract, fraud/misrepresentation, and breach of implied warranty.1 Plaintiff now

seeks the entry of default judgment on these claims and requests actual damages, punitive damages, attorney’s fees, costs, and interest. A “default judgment may not be entered until the amount of damages has been ascertained.” Reg'l Dist. Council v. Mile High Rodbusters, Inc., 82 F. Supp. 3d 1235, 1243 (D. Colo. 2015). “Damages may be awarded only if the record adequately reflects the basis for award via a hearing or a demonstration by detailed affidavits establishing the necessary

facts.” DeMarsh v. Tornado Innovations, L.P., No. 08-2588-JWL, 2009 WL 3720180, at *2 (D. Kan. Nov. 4, 2009) (quotation omitted). The plaintiff must “establish that the amount requested is reasonable under the circumstances.” Mathiason v. Aquinas Home Health Care, Inc., 187 F. Supp. 3d 1269, 1275 (D. Kan. 2016).2 Plaintiff first requests actual and consequential damages based on Defendant’s

negligent injury to its property. Under Oklahoma law,3 the measure of damages for breach of an obligation not arising from contract is “the amount which will compensate for all

1 “Upon an entry of default, the Court takes all the well-pleaded facts in a complaint as true.” Richway, LLC v. SX Three, LLC, No. CIV-25-21-SLP, 2025 WL 971750, at *1 (W.D. Okla. Mar. 31, 2025). Based on Plaintiff’s uncontested factual averments and other evidentiary materials in the record, the Court is satisfied that there is a legitimate basis for the entry of judgment on these claims.

2 Based on the evidence and argument submitted by Plaintiff, the Court finds that a formal hearing on damages is unnecessary.

3 As a federal court sitting in diversity, the Court applies the substantive law of the forum state, Oklahoma. Hayes Family Trust v. State Farm Fire & Cas. Co., 845 F.3d 997, 1005 (10th Cir. 2017). detriment proximately caused thereby, whether it could have been anticipated or not.” Okla. Stat. tit. 23, § 61. For injury to personal property that “has been partially damaged

by the negligence of another” but is “susceptible to repair at reasonable expense,” the measure of damages includes “the cost of the repairs and the value of the loss of the use of it while it is being repaired.” Brennen v. Aston, 84 P.3d 99, 101 (Okla. 2003). Additionally, where “a plaintiff suffers injury as an indirect result of property damage, that may be compensable by consequential damages.” Frank Bartel Transportation, Inc. v. State ex rel. Murray State Coll., 540 P.3d 480, 485 (Okla. 2023). Plaintiff has supported his request for

damages arising from Defendant’s negligent repairs of the engine by including invoices and an affidavit showing that it paid Defendant $32,927.44 for repairs that were not fully or properly performed, it paid $7,097.47 and $5,189.93 to replace the engine following Defendant’s negligent repairs, it incurred expenses related to loss of use of the truck in the amount of $95,774.36, and it incurred consequential damages in the amount of $10,800.07

for expenses and wages related to fixing the truck. Based on the material submitted by Plaintiff, the Court concludes that it is entitled to recover $151,789.27 in actual damages.4 Plaintiff additionally seeks punitive damages based on Defendant’s misconduct. To obtain punitive damages under Oklahoma law, the plaintiff must prove “by clear and convincing evidence that ‘[t]he defendant has been guilty of reckless disregard for the

4 Plaintiff does not advance an argument in favor of separately awarding damages for its claims for breach of contract, fraud, or breach of warranty. Regardless, double recovery is not permitted in Oklahoma. Kruchowski v. Weyerhaeuser Co., 2008 OK 105, ¶ 33, 202 P.3d 144, 153, as corrected (Dec. 19, 2008) (“Oklahoma law allows only one recovery to make a plaintiff whole.”). rights of others,’ or that ‘[t]he defendant has acted intentionally and with malice towards others.’” McGinley v. Am. Dump Trucks, Inc., No. CIV-20-408-G, 2021 WL 4517687, at

*4 (W.D. Okla. Sept. 30, 2021) (quoting Okla. Stat. tit. 23, § 9.1(B)-(D)). “Reckless disregard is established by showing that the defendant ‘was either aware, or did not care, that there was a substantial and unnecessary risk that [his] conduct would cause serious injury to others.’” Id. (quoting Gowens v. Barstow, 364 P.3d 644, 652 (Okla. 2015)). Oklahoma law sets out several factors that a factfinder may evaluate in determining whether punitive damages are warranted. Okla. Stat. tit. 23, § 9.1(A).

In support of its request for punitive damages, Plaintiff argues that (1) Defendant’s failure to correctly repair the engine of a large tractor trailer puts the public at risk, (2) Defendant profited by charging for parts that could not have been installed and failed to disclose large markups on parts, (3) Defendant concealed its misconduct which was not discoverable until the engine failed and was disassembled, (4) Defendant was aware of its

fraudulent conduct, (5) Defendant’s attitude upon discovery of the misconduct is shocking in that they claimed without any proof that Plaintiff switched the engine, and (6) several employees of Defendant had knowledge of the misconduct but did nothing to stop it. As evidence of Defendant’s intentional or reckless misconduct, Plaintiff primarily relies on the deposition testimony of Defendant’s shop foreman who testified that customers were

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