Gaskill v. Firmso LLC

CourtDistrict Court, S.D. Texas
DecidedJanuary 3, 2025
Docket4:24-cv-01111
StatusUnknown

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

Bluebook
Gaskill v. Firmso LLC, (S.D. Tex. 2025).

Opinion

UNITED STATES DISTRICT COURT January 03, 2025 SOUTHERN DISTRICT OF TEXAS Nathan Ochsner, Clerk HOUSTON DIVISION

JAMES GASKILL, § § § Plaintiff, § § v. § § NO. 4:24-cv-1111 FIRMSO LLC, § § § Defendant. § §

MAGISTRATE JUDGE’S REPORT AND RECOMMENDATION ON PLAINTIFF’S MOTION FOR DEFAULT JUDGMENT

Before the Court is Plaintiff’s motion for default judgment. Pl.’s Mot., ECF No. 10.1 Plaintiff James Gaskill claims Defendant Firmso LLC violated the Fair Labor Standards Act (“FLSA”) and seeks to recover actual damages, liquidated damages, attorneys’ fees, court costs, and post-judgment interest. Defendant failed to answer the complaint or appear at the evidentiary hearing this Court held on the motion for default judgment. Based on a careful review of the complaint, the briefing, the evidence, and argument presented at hearing, the Court recommends that the motion for default judgment be granted. Default judgment should be entered against Defendant and

1 The district judge to whom this case is assigned referred this motion for disposition. Order, ECF No. 11. Pursuant to 28 U.S.C. § 636(b)(1)(A), a motion for default judgment is a dispositive motion appropriate for a Report and Recommendation. Calsep, Inc. v. Intelligent Petroleum Software Sols., LLC, No. 4:19-CV-1118, 2020 WL 7249831, at *1 (S.D. Tex. Nov. 18, 2020), adopted, No. 4:19-CV-1118, 2020 WL 7247781 (S.D. Tex. Dec. 8, 2020). damages in the follow amounts: $164,767.11 in actual damages: $164,767.11 in liquidated damages, $60,000.00 in attorneys’ fees, $250.00 in court costs, and 4.16%

in post-judgment interest. I. BACKGROUND FACTS. At the hearing, Plaintiff testified that Defendant is a drilling company that works on the construction of pipelines under other structures, where traditional

digging for pipelines cannot be done. Plaintiff worked for Defendant as a project manager from June 1, 2023, until October 31, 2023. Pl.’s Compl., ECF No. 1 ¶¶ 5, 23. As a project manager, his duties included supervision of worksites, crew

management, inspection, investigation, business development, and operations management. Id. ¶ 24. Defendant paid Plaintiff an annual salary of $224,640.00. Id. ¶ 27. Defendant controlled Plaintiff’s work schedule, duties, protocols, applications, assignments, and employment conditions and provided the facilities, vehicles, and

necessary equipment to perform his duties. Id. ¶¶ 24, 25. Plaintiff regularly worked 80 or more hours in a week. Id. ¶ 29. Defendant failed to pay Plaintiff wages on June 23, 2023, July 21, 2023,

August 4, 2023, August 11, 2023, August 18, 2023, August 25, 2023, September 8, 2023, September 22, 2023, September 29, 2023, October 13, 2023, October 20, 2023, and October 27, 2023, totaling “$56,16[0].00.” Id. ¶ 30. Additionally, Defendant did not reimburse Plaintiff’s expenses in the amount of $20,697.57. Id. ¶ 31. Plaintiff complained to Defendant about the unpaid wages and expenses. Id. ¶ 48. Plaintiff also testified that he complained to the Defendant about its failure

to pay his crew. Defendant did not investigate or escalate Plaintiff’s claims and terminated his employment. Id. ¶¶ 48, 50. Plaintiff alleges that, because of the termination, he lost wages in the amount

of $108,607.19 for periods in which he was unable to secure employment and for accepting employment that paid less than his Firmso salary. Gaskill Aff., ECF No. 13. Plaintiff seeks actual damages in the amount of $164,767.11,2 liquidated damages in the amount of $164,767.11, attorneys’ fees based on a 35 percent

contingency fee,3 $250.00 in court costs,4 and post-judgment interest.5 II. DEFAULT JUDGMENT UNDER FEDERAL RULE OF CIVIL PROCEDURE 55. Under Federal Rule of Civil Procedure 55(a), “[w]hen a party against whom judgment for affirmative relief is sought has failed to plead or otherwise defend, and that failure is shown by affidavit or otherwise, the clerk must enter the party’s

default.” FED. R. CIV. P. 55(a). After default is entered, a party may ask the court to

2 Based on a summation of the figures provided in the Complaint, ECF No. 1, for accrued but unpaid wages ($56,160.00) and Gaskill Aff., ECF No. 13, for wages Plaintiff would have made had he not been terminated ($108,607.11). Plaintiff states in the affidavit that the latter amount is $108,607.19, but the numbers provided in the affidavit add up to $108,607.11. 3 As stated in the evidentiary hearing on November 14, 2024, Minute Entry, ECF No. 15. 4 As stated in the evidentiary hearing. 5 As stated in the complaint. enter a default judgment, and the “court may conduct hearings or make referrals— preserving any federal statutory right to a jury trial—when, to enter or effectuate

judgment, it needs to: (A) conduct an accounting; (B) determine the amount of damages; (C) establish the truth of any allegation by evidence; or (D) investigate any other matter.” FED. R. CIV. P. 55(b)(2).

A plaintiff must submit evidence that the defendant has been properly served with the summons, complaint, and the default judgment motion. See James Avery Craftsman, Inc. v. Sam Moon Trading Enters., Ltd., No. 16-CV-463, 2018 WL 4688778, at *3 (W.D. Tex. July 5, 2018) (citing Bludworth Bond Shipyard, Inc. v.

M/V Caribbean Wind, 841 F.2d 646, 649-51 (5th Cir. 1988)); Hazim v. Schiel & Denver Book Grp., No. H-12-1286, 2013 WL 2152109, at *1 (S.D. Tex. May 16, 2013); S.D. TEX. LOCAL R. 5.5 (a default judgment motion “must be served on the

defendant-respondent by certified mail (return receipt requested)”). Without proper service, a court does not have personal jurisdiction over the defendant, and as a result, any default judgment is void. See Recreational Props., Inc. v. Sw. Mortg. Serv. Corp., 804 F.2d 311, 314 (5th Cir. 1986).

A motion for default judgment requires the court to determine: “(1) if default judgment is procedurally appropriate; (2) if plaintiff has presented a colorable claim; and (3) how to calculate damages.” Vela v. M&G USA Corp., No. 2:17-CV-13, 2020

WL 421188, at *1 (S.D. Tex. Jan. 27, 2020). The court must consider whether: (1) material issues of fact are at issue; (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. Lindsey v. Prive Corp., 161 F.3d 886, 893 (5th Cir. 1998).

Default judgments are a drastic remedy and are disfavored by the courts. Charlton L. Davis & Co., P. C. v. Fedder Data Ctr., Inc., 556 F.2d 308, 309 (5th Cir. 1977). “A default judgment is unassailable on the merits but only so far as it is supported by the well-pleaded allegations, assumed to be true.” Wooten v. McDonald

Transit Assocs, Inc., 788 F.3d 490, 496 (5th Cir. 2015) (quoting Nishimatsu Constr. Co., Ltd. v. Hous. Nat’l Bank, 515 F.2d 1200, 1206 (5th Cir. 1975)). “There must be a sufficient basis in the pleadings for the judgment entered.” Nishimatsu Constr. Co.,

515 F.2d at 1206.

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