Huntington National Bank v. Campisi Environmental Associates, Inc.

CourtDistrict Court, D. Minnesota
DecidedApril 22, 2022
Docket0:21-cv-02089
StatusUnknown

This text of Huntington National Bank v. Campisi Environmental Associates, Inc. (Huntington National Bank v. Campisi Environmental Associates, Inc.) is published on Counsel Stack Legal Research, covering District Court, D. Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Huntington National Bank v. Campisi Environmental Associates, Inc., (mnd 2022).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA

Huntington National Bank, File No. 21-cv-2089 (ECT/DTS) successor-by-merger to TCF National Bank,

Plaintiff,

v. OPINION AND ORDER

Campisi Environmental Associates, Inc., doing business as Corporate Environmental Advisors; and Joseph S. Campisi,

Defendants. ________________________________________________________________________ Daniel N. Moak and Mark G. Schroeder, Taft Stettinius & Hollister LLP, Minneapolis, MN, for Plaintiff Huntington National Bank.

Plaintiff Huntington National Bank, successor-by-merger to TCF National Bank, seeks entry of a default judgment against Defendants Campisi Environmental Associates, Inc., and Joseph S. Campisi. ECF No. 12. Huntington alleges that Defendants breached their obligations by failing to make required monthly payments as required under the parties’ credit agreements. The judgment Huntington seeks against Defendants (jointly and severally) would include actual damages of $273,466.22, attorneys’ fees and expenses, and post-judgment interest under 28 U.S.C. § 1961. Huntington’s motion will be granted.1

1 The Clerk properly entered Defendants’ default. ECF No. 11. The summons and complaint were served on Defendant Joseph S. Campisi on September 22, 2021, ECF No. 5, and on Defendant Campisi Environmental Associates on November 24, 2021, and they have not responded or otherwise appeared. See generally, Docket; see also Schroeder Decl. [ECF No. 10] ¶¶ 6-8. Plaintiff also has served the motion for default judgment and The basic process for determining whether a default judgment should be entered is straightforward. Entry of default means that the “factual allegations of the complaint, except those relating to the amount of damages, will be taken as true.” 10A Mary K. Kane,

Federal Practice and Procedure § 2688.1 (4th ed. Apr. 2022 Update) (footnotes omitted). Thus, it must first be determined whether the taken-as-true factual allegations of the complaint “constitute a legitimate cause of action, since a party in default does not admit mere conclusions of law.” Marshall v. Baggett, 616 F.3d 849, 852 (8th Cir. 2010) (quoting Murray v. Lene, 595 F.3d 868, 871 (8th Cir. 2010)). If the taken-as-true allegations of the

complaint constitute a legitimate cause of action, then the amount and other terms of the default judgment must be ascertained. See Hagen v. Sisseton-Wahpeton Cmty. Coll., 205 F.3d 1040, 1042 (8th Cir. 2000). Start with the factual allegations in the complaint, which are accepted as true. Huntington National Bank (“Huntington”) is a national banking association, and a

successor-by-merger to TCF National Bank (“TCF”). Compl. [ECF No. 1] ¶ 1. The detailed complaint describes a financing arrangement between TCF, Defendant Campisi Environmental Associates Inc.’s (“Campisi Environmental”), and Defendant Joseph S. Campisi, whereby TCF financed Campisi Environmental’s purchase of software and equipment. On September 10, 2020, Campisi Environmental purchased software and

supporting papers on Defendants. ECF Nos. 18. A hearing on the motion was held on April 18, 2022. ECF No. 19. Defendant did not appear or otherwise respond. equipment from Bright Vanguard LLC, a broker in San Antonio, Texas, as reflected in an Invoice attached to the Complaint. Compl. ¶¶ 2, 7, Ex. A. To finance this purchase, Campisi Environmental and its Guarantor, Joseph

Campisi, executed several agreements with TCF, as described in the complaint: an Installment Payment Agreement (“IPA”), a Pay Proceeds and Acceptance Confirmation (“Confirmation”), a Continuing Guaranty (“Guaranty”), and an Authorization for Automatic Electronic Payment (“Authorization”) (together, the “Credit Agreements”). See Compl. ¶¶ 7–32. Campisi Environmental and TCF entered into the IPA on September 11,

2020. The IPA set forth the terms of a loan from TCF to Campisi Environmental for $284,470.67 to finance Campisi Environmental’s software and equipment purchase. Compl. ¶ 8, Ex. B. The IPA provided that Campisi Environmental was to make monthly payments of $5,550.42 to TCF over 60 months. Compl. ¶ 9, Ex. B. The IPA provided other rights and remedies to TCF, including TCF’s right to impose a late fee or charge

interest for late payments, and TCF’s right to obtain attorneys’ fees, costs, and expenses associated with exercising any right or remedy available to it under the IPA. Id. ¶¶ 10–15, Ex. B. The IPA was secured by a Guaranty from Joseph Campisi in favor of TCF. See Compl. ¶ 23, Ex. E. Under the Guaranty, Joseph Campisi “unconditionally and absolutely guarantee[d] the full and prompt performance” of Campisi Environmental’s payment (and

other) obligations under the IPA. Id. ¶ 24. In connection with the IPA, Campisi Environmental provided TCF with the Confirmation, dated September 11, 2020. Id. ¶ 18, Ex. D. The Confirmation confirmed that the software and equipment had been delivered satisfactorily and as described in the IPA, and it authorized TCF to pay Bright Vanguard the financed amount. Id. ¶ 19, Ex. D. Accordingly, TCF funded the financed amount. Id. ¶ 22, Ex. D. In June 2021, Campisi Environmental stopped making its monthly payments. Id.

¶ 29, see also Ex. H; Shamblott Decl. [ECF No. 16] ¶ 5. On July 20, 2021, TCF sent Defendants a notice of default. Id. ¶ 28, Ex. G. Defendants still did not pay, and on September 17, 2021, TCF sent another notice of default and demanded payment of all outstanding amounts from Campisi Environmental and Joseph Campisi, pursuant to the terms of the parties’ Credit Agreements. Id. ¶¶ 30-31, Ex. H.

These taken-as-true allegations constitute legitimate causes of action for breach of contract against Campisi Environmental and Joseph Campisi, see id. ¶¶ 34–48.2 Minnesota law applies because the IPA and the Guaranty contain Minnesota choice-of-law provisions. Ex. A ¶ 11; Ex. E. Under Minnesota law, the elements of a breach-of-contract claim are “(1) formation of a contract, (2) performance by plaintiff of any conditions precedent to

his right to demand performance by the defendant, and (3) breach of the contract by defendant.” Park Nicollet Clinic v. Hamann, 808 N.W.2d 828, 833 (Minn. 2011). Huntington plainly and plausibly pleads these elements against both Defendants. The formation of the IPA and the Guaranty, and other agreements are alleged in detail, and nothing about Huntington’s allegations leaves room to question the validity of either of

these two contracts’ formation. The IPA imposed no conditions precedent to TCF’s ability

2 Although the Complaint includes six counts, Huntington’s Motion for Default Judgment focuses only on Counts I & II—for breach of contract against Campisi Environmental and Joseph Campisi, respectively. Mem. in Supp. [ECF 14] at 6. to accelerate payments upon Campisi Environmental’s failure to make payment, see Ex. B. ¶¶ 7, 8, but if giving notice was a condition precedent to triggering TCF’s remedies under the IPA or any other contract, then Huntington has alleged that it gave notice. See Compl.

¶¶ 28–33; Exs. G, H. Huntington’s allegations show that Campisi Environmental and Joseph Campisi, as guarantor, did not fulfill their payment obligations. Compl. ¶¶ 29, 33.

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