Castillo v. Colmenares

CourtDistrict Court, S.D. Florida
DecidedSeptember 3, 2025
Docket1:21-cv-24221
StatusUnknown

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

Bluebook
Castillo v. Colmenares, (S.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

CASE NO. 21-24221-CIV-LENARD/LOUIS

PABLO DARIO CASTILLO,

Plaintiff,

v.

FERNANDO COLMENARES,

Defendant, ________________________________/

Counter-Plaintiff,

Counter-Defendant, _____________________________________________/

ORDER

THIS CAUSE is before the Court on the Plaintiff Pablo Castillo’s (“Plaintiff”) ore tenus Motion for Default Judgment (“Motion”), the findings of which are adopted and supplemented in this Order, and the Notice of Apology and Explanation for Missed Pretrial Conference (“Apology”) (D.E. 309) filed by the Defendant Fernando Colmenares (“Defendant”).1 On December 10, 2024, the Court entered an Order setting the pretrial conference for June 16, 2025, in anticipation of the trial in this case on June 30, 2025. This

case has been previously set for trial three times and has been continued each time. As more than three and a half years have elapsed since the filing of this case, the resolution of this matter is long overdue. On June 16, 2025, at the final scheduled pretrial conference, the Defendant, representing himself pro se, failed to appear. Plaintiff’s counsel was present, and the Court waited 30 minutes for the Defendant to arrive. At no time did the Defendant contact by any

means the Plaintiff’s counsel, the Court’s chambers, or the Clerk’s office by phone, email, or in person to report any delay or inability to timely attend the pretrial conference. After waiting 30 minutes, the Plaintiff moved for default judgment, which the Court granted. As an additional sanction, the Court entered a sua sponte dismissal of the counterclaim. Two hours after the conclusion of the pretrial conference, the Defendant filed his Apology,

claiming to have missed the pretrial conference due to car troubles. D.E. 309. Having considered the pleadings, the Motion, the docket, and otherwise being fully informed, the Court orders as follows. I. Background The Plaintiff filed the Complaint (“Complaint”) (D.E. 1) on December 1, 2021,

alleging the following Counts against the Defendant: (I) breach of fiduciary duty; (II)

1 The Court construes the Apology as a Motion to Set Aside Default. Plaintiff did not file a response to the Apology. As the Apology was filed on June 16, time has now expired for the Plaintiff to respond to the Apology. fraudulent misappropriation;2 (III) conversion; and (IV) constructive trust. D.E. 1 at 4-10. The Complaint alleges that the Court has diversity jurisdiction over this case pursuant to

28 U.S.C. § 1332. The Plaintiff is an Argentine citizen who resides in Argentina. D.E. 1 at 1. The Defendant is a citizen of Florida. Id. The Plaintiff alleges an amount in controversy greater than $75,000. Id. The Defendant filed his Answer, Affirmative Defenses, and Counterclaim (“Counterclaim”) (D.E. 34) on April 21, 2022. On December 10, 2024, the Court entered an Order (D.E. 294) setting the trial in this case to begin on June 30, 2025, and set the pretrial conference for June 16, 2025, at

9:00 a.m. On March 7, 2025, the Court entered another Order (“Scheduling Order”) (D.E. 301) which again set the start date of the trial to June 30 and the date of the pretrial conference to June 16. D.E. 301. However, the starting time of the pretrial conference was set to 9:30 a.m. Id. At the pretrial conference, the Plaintiff’s counsel timely appeared before the Court.

The Defendant failed to appear at 9:30 a.m. The Court then waited until 10:00 a.m. for the Defendant to make an appearance. The Defendant did not appear by that time or at any time afterward, nor did he contact the Court or the Plaintiff’s counsel. At 10:00 a.m. the Plaintiff’s counsel moved for default against the Defendant. The court granted the Motion and dismissed the Counterclaim as a further. The Court notes that the Defendant did not

attempt to explain his absence until several hours later.

2 The Complaint has since been amended to voluntarily dismiss Count II. D.E. 263. II. Applicable Law Federal Rule of Civil Procedure 16 covers pretrial conferences and gives district

judges the authority to impose sanctions on a party that fails to appear at a scheduling or other pretrial conference or fails to obey a scheduling or other pretrial order. Fed. R. Civ. P. 16(f)(1)(A), (C). FRCP 16(f)(1) provides that these sanctions may include those authorized by FRCP 37(b)(2)(A)(ii)-(vii). Fed. R. Civ. P. 16(f)(1). Among the sanctions which a court may impose under FRCP 37, a court is empowered to dismiss a case or enter default judgment. Fed. R. Civ. P. 37(b)(2)(A)(v)-(vi).

Under Rule 55, a Court may enter default judgment “when a party against whom a judgment for affirmative relief is sought has failed to plead or otherwise defend[.]” Fed. R. Civ. P. 55(a). Default judgment “is a sanction of last resort, reserved for cases in which the party's misconduct is willful or in bad faith — mere negligence is not enough.” Suarez v. Marbridge Restoration, LLC, No. 24-22780-CIV, 2025 WL 1433626, at *2 (S.D. Fla. Mar.

6, 2025) (citing Malautea v. Suzuki Motor Co., Ltd., 987 F.2d 1536, 1542 (11th Cir. 1993)). Nevertheless, default judgment is an appropriate sanction against a party that has engaged in a pattern of bad faith which culminates in that party’s failure to appear at a scheduled conference. See Marbridge, No. 24-22780-CIV, 2025 WL 1433626, at *2 (“Courts routinely enter default judgment where a party repeatedly flouts court orders, skips

hearings, or obstructs discovery.). However, “[b]ecause a defaulting defendant is not held to admit facts that are not well pleaded or to admit conclusions of law, the court must first determine whether the pleadings provide a sufficient basis for judgment.” Id. Accordingly, while a court may enter default against a defendant for failure to comply with court orders or failure to appear at scheduled hearings, a plaintiff must nevertheless demonstrate that their case merits default judgment.

Per Rule 41(b), a Court may order the dismissal of a case if the plaintiff or counter- plaintiff fails to comply with the Federal Rules of Civil Procedure. Fed. R. Civ. P. 41(b)- (c). Dismissal of an action, like default, is a sanction that is not lightly entered. Dismissal of a case is warranted where a party engages in a pattern of willful delay and deliberate refusal to comply with the directions of the court. Goforth v. Owens, 766 F.2d 1533, 1535 (11th Cir. 1985). The standard for dismissal under Rule 41(b) is whether there is a “clear

record of delay or willful contempt and a finding that lesser sanctions would not suffice.” Id.

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Castillo v. Colmenares, Counsel Stack Legal Research, https://law.counselstack.com/opinion/castillo-v-colmenares-flsd-2025.