Canal Insurance Company v. Magallon Trucking, Inc.

CourtDistrict Court, N.D. Texas
DecidedJanuary 25, 2022
Docket4:21-cv-01170
StatusUnknown

This text of Canal Insurance Company v. Magallon Trucking, Inc. (Canal Insurance Company v. Magallon Trucking, Inc.) is published on Counsel Stack Legal Research, covering District Court, N.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Canal Insurance Company v. Magallon Trucking, Inc., (N.D. Tex. 2022).

Opinion

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS FORT WORTH DIVISION

CANAL INSURANCE COMPANY,

Plaintiff.

v. No. 4:21-cv-1170-P

MAGALLON TRUCKING, INC. ET AL.,

Defendants.

MEMORANDUM OPINION & ORDER Before the Court are Plaintiff Canal Insurance Company’s Motions for Default Judgment against Defendants Saul Magallon and Magallon Trucking, Inc. ECF Nos. 16, 18. After consideration, the Court will GRANT the Motions and will issue a Declaratory Judgement that Plaintiff has no duty to defend or indemnify these Defendants. BACKGROUND On October 22, 2021, Plaintiff Canal Insurance Company initiated this action seeking a declaratory judgment against Defendants Saul A. Magallon, Magallon Trucking, Inc., and Miguel Ulloa-Rodriguez. Pl.’s Compl., ECF No. 1. Miguel Ulloa Rodriguez is a driver for Magallon Trucking who was injured while loading a delivery truck. Id. ¶ 4.1. He sued Magallon Trucking and its owner Saul Magallon in state court, alleging his injuries were a result of his employer’s negligence and seeking recovery of damages. Id. ¶ 4.2–4.4. This underlying litigation is on-going. Canal Insurance provided a commercial automobile insurance policy to Magallon Trucking, Inc. that was effective at the time of the accident. Id. ¶ 5.1. The relevant portions of the policy detail that Canal Insurance will “pay all sums an ‘insured’ legally must pay as damages because of ‘bodily injury’ . . . to which this insurance applies” and that Canal Insurance has “the right and duty to defend any ‘insured’ against a ‘suit’ asking from such damages . . . . However, [Canal has] no duty to defend any ‘insured’ against a ‘suit’ . . . to which this insurance does not apply.” Id. ¶ 5.2. The policy creates a coverage exclusion that applies to “’bodily injury’ to: (a) an ‘employee’ of the ‘insured’ arising out of and in the course of: (1) employment by the ‘insured;’ or (2) performing the duties related to the conduct of the ‘insured’s’ business . . . . This exclusion applies: (1) whether the ‘insured’ may be liable as an employer or in any other capacity.” Id. ¶ 5.5. Due to the litigation between Magallon Trucking and Ulloa-Rodriguez, Canal Insurance is seeking a declaratory judgment that, under its insurance policy, it has no duty to defend or to indemnify Magallon Trucking or its owner Saul Magallon for Ulloa- Rodriguez’s claims. Id. ¶ 1.1, 1.3. Canal Insurance served Defendants Saul Magallon and Magallon Trucking, Inc. on November 5, 2021, and served Miguel Ulloa-Rodriguez on November 13. ECF Nos. 6–8. On December 3, 2021, Defendant Ulloa- Rodriguez filed his answer. ECF No. 10. To date, Defendants Saul Magallon and Magallon Trucking, Inc. have not filed an answer or otherwise responded to Plaintiff’s complaint and on December 17, 2021, Plaintiff requested that the Clerk of Court enter a default against these defendants. ECF Nos. 15, 17. The Clerk entered default against Defendants Saul Magallon and Magallon Trucking, Inc. ECF Nos. 19– 20. Canal Insurance filed for default judgment against these Defendants. ECF Nos. 16, 18. LEGAL STANDARD Federal Rule of Civil Procedure 55 sets forth the conditions under which default may be entered against a party, as well as the procedure by which a party may seek the entry of default judgment. See FED. R. CIV. P. 55. There are three stages to the entry of a default judgment. First, a default occurs “when a defendant has failed to plead or otherwise respond to the complaint within the time required by the Federal Rules.” N.Y. Life Ins. Co. v. Brown, 84 F.3d 137, 141 (5th Cir. 1996); see also FED. R. CIV. P. 55(a). Second, an entry of default may be entered “when the default is established by affidavit or otherwise.” N.Y. Life Ins. Co., 84 F.3d at 141 (citing FED. R. CIV. P. 55(a)). Third, a plaintiff may then 2 apply to the clerk or the Court for a default judgment after an entry of default is made. Id. A default judgment, however, may not be entered against an individual in military service until an attorney is appointed to represent the defendant. 50 U.S.C. § 521. “Default judgments are a drastic remedy, not favored by the Federal Rules and resorted to by courts only in extreme situations.” Lewis v. Lynn, 236 F.3d 766, 767 (5th Cir. 2001) (internal quotation marks omitted). Moreover, “a party is not entitled to a default judgment as a matter of right, even where the defendant is technically in default.” Id. (quoting Ganther v. Ingle, 75 F.3d 207, 212 (5th Cir. 1996) (per curiam)). “There must be a sufficient basis in the pleadings for the judgment entered.” Nishimatsu Constr. Co. v. Hous. Nat’l Bank, 515 F.2d 1200, 1206 (5th Cir. 1975). Only well-pleaded facts, not conclusions of law, are presumed to be true. Id. Default judgment “should not be granted on the claim, without more, that the defendant had failed to meet a procedural time requirement.” Mason & Hanger–Silas Mason Co., Inc. v. Metal Trades Council, 726 F.2d 166, 168 (5th Cir. 1984) (per curiam). In determining whether the entry of a default judgment is appropriate, courts have developed a three-part analysis. Ramsey v. Delray Cap. LLC, No. 3:14-CV-3910-B, 2016 WL 1701966, at *2 (N.D. Tex. Apr. 28, 2016). First, courts look to whether a default judgment is procedurally warranted. See Lindsey v. Prive Corp., 161 F.3d 886, 893 (5th Cir. 1998). The Lindsey factors are relevant to this inquiry. Accordingly, the Court may consider whether: (1) material issues of fact exist; (2) there has been substantial prejudice; (3) the grounds for default are clearly established; (4) the default was caused by a good faith mistake or excusable neglect; (5) the harshness of a default judgment; and (6) the court would think itself obliged to set aside the default on the defendant’s motion. Id. Second, courts analyze the substantive merits of the plaintiff’s claims and determine if there is a sufficient basis in the pleadings for the judgment. See Nishimatsu Constr. Co., 515 F.2d at 1206 (stating that “default is not treated as an absolute confession by the defendant of his liability and of the plaintiff’s right to recover”). To that end, the Court is 3 to assume because of its default, defendant admits all well-pleaded facts, but not to those facts that are not well-pleaded or other conclusions of law. Id. Third, courts determine what form of relief, if any, the plaintiff should receive. See Ins. Co. of the W. v. H & G Contractors, Inc., No. C- 10-390, 2011 WL 4738197, at *4 (S.D. Tex. Oct. 5, 2011) (“A defendant’s default concedes the truth of the allegations of the Complaint concerning the defendant’s liability, but not damages.”). When the “amount of damages can be determined with mathematical calculation by reference to the pleadings and supporting documents, a hearing is unnecessary.” Ramsey, 2016 WL 1701966, at *3 (citing James v. Frame, 6 F.3d 307, 310 (5th Cir. 1993)). ANALYSIS Applying this three-part analysis, the Court concludes that a default judgment is procedurally warranted and supported by a sufficient factual basis in Plaintiffs’ Complaint. A. Default judgment is procedurally warranted.

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Bluebook (online)
Canal Insurance Company v. Magallon Trucking, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/canal-insurance-company-v-magallon-trucking-inc-txnd-2022.