HYC LOGISTICS INC. v. OJCOMMERCE, LLC, doing business as OJ Commerce, LLC, and JACOB WEISS

CourtDistrict Court, W.D. Tennessee
DecidedDecember 8, 2025
Docket2:23-cv-02050
StatusUnknown

This text of HYC LOGISTICS INC. v. OJCOMMERCE, LLC, doing business as OJ Commerce, LLC, and JACOB WEISS (HYC LOGISTICS INC. v. OJCOMMERCE, LLC, doing business as OJ Commerce, LLC, and JACOB WEISS) is published on Counsel Stack Legal Research, covering District Court, W.D. Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
HYC LOGISTICS INC. v. OJCOMMERCE, LLC, doing business as OJ Commerce, LLC, and JACOB WEISS, (W.D. Tenn. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TENNESSEE WESTERN DIVISION

HYC LOGISTICS INC., ) ) Plaintiff, ) ) No. 2:23-cv-02050-TLP-tmp v. ) ) JURY DEMAND OJCOMMERCE, LLC, doing business as ) OJ Commerce, LLC, and JACOB WEISS, ) ) Defendants. )

ORDER ON MOTIONS FOR ATTORNEYS’ FEES

In December 2024, the Court held a jury trial in this case. (ECF Nos. 289, 294–97.) And the jury returned a verdict finding that Defendant OJCommerce, LLC (“OJC”) breached its contract with Plaintiff HYC Logistics, Inc. (“HYC”) and that, in response to the breach, HYC properly exercised its contractual lien right. (ECF No. 302.) But the jury also found that HYC engaged in misrepresentation and deceived port authorities in Los Angeles, California, violating the Tennessee Consumer Protection Act (“TCPA”). (Id.) The Parties then filed post-trial motions (ECF Nos. 303, 304, 310), and the Court vacated the TCPA award (ECF No. 342). The Parties now move for attorneys’ fees. (ECF Nos. 349, 351.) For the reasons explained below, the Court DENIES OJC’s Motion and GRANTS IN PART HYC’s Motion. BACKGROUND1 HYC provides logistics services to international and domestic companies. And in 2022,

1 See Order Denying Summary Judgment (ECF No. 259) and Order on Post-Trial Motions (ECF No. 342) for a more detailed background. OJC hired HYC to coordinate shipping and transportation for its goods. Relying on the trucking company 562 Express, HYC fulfilled the transportation requests for many of OJC’s shipments. But OJC disputed certain charges and fees instead of timely paying all its invoices. In response to this nonpayment, HYC exercised its contractual lien right and had 562 Express pick up and hold nine containers that were shipped to the Los Angeles Port for OJC.

HYC then sued OJC here, seeking a declaratory judgment confirming its right to enforce its contractual lien and to sell the contents of the nine containers to offset OJC’s debt. (ECF No. 1.) HYC also alleged breach of contract against OJC to recover expenses and damages for the services it provided. (Id.) And, relevant to these motions, OJC counterclaimed and asserted fraud, misrepresentation, and TCPA violations. (ECF No. 49.) At the end of the trial, the jury returned a verdict for HYC on the contract and lien claims. (ECF No. 302.) And it found for OJC on its misrepresentation and TCPA claims. (Id.) But the Court then vacated the TCPA award in its ruling on the Parties’ renewed motions for judgment as a matter of law under Federal Rule of Civil Procedure 50(b). (ECF No. 342.) The Parties now move for attorneys’

fees. (ECF Nos. 349, 351.) LEGAL STANDARD When a federal court exercises its diversity jurisdiction over a case, state law governs an attorneys’ fee award. SHH Holdings, LLC v. Allied World Specialty Ins. Co., 65 F.4th 830, 836– 37 (6th Cir. 2023) (citation omitted). So Tennessee law applies here. And Tennessee courts follow the “American Rule” when addressing attorneys’ fees. See Colley v. Colley, 715 S.W.3d 293, 302 (Tenn. 2025); see also Hometown Folks, LLC v. S & B Wilson, Inc., 643 F.3d 520, 533 (6th Cir. 2011). Under that rule, parties in civil cases typically pay their own attorneys’ fees unless “(1) a contractual or statutory provision creates a right to recover attorney’s fees; or (2) some other recognized exception to the American Rule applies.” Colley, 715 S.W.3d at 302 (citation omitted). The party seeking attorneys’ fees “bears the burden of showing [that] an exception to the American Rule” applies. Id. at 303 (citation omitted). With that said, the United States Supreme Court has noted that “[a] request for attorney’s fees should not result in a second major litigation.” Hensley v. Eckerhart, 461 U.S. 424, 437 (1983). The Court addresses

OJC’s Motion before turning to HYC’s Motion. OJC’S MOTION FOR ATTORNEYS’ FEES OJC moves for $616,089.50 in attorneys’ fees. (ECF No. 349.) This Court can grant OJC’s request only if those fees are authorized by statute or contract, or if another exception to the American Rule applies. See Colley, 715 S.W.3d at 302. OJC does not argue—for good reason—that either of the first two categories apply. (See ECF No. 349 at PageID 5876–80). There is no statute allowing attorneys’ fees in fraud cases, and OJC did not prevail on any contract claim.2 And OJC does not claim it falls into any of Tennessee’s traditionally recognized exceptions to the American Rule. See, e.g., Pullman Standard, Inc. v. Abex Corp., 693 S.W.2d

336, 338–39 (Tenn. 1985) (creating narrow exceptions to include “implied indemnity agreement[s]” and the “tort of deceit”); House v. Est. of Edmondson, 245 S.W.3d 372, 377 (Tenn. 2008) (recognizing the “common fund doctrine” as another exception). Rather, OJC argues that “Tennessee law unequivocally entitles an award of attorneys’ fees to a prevailing party on a fraud claim, recognizing the unfair burden on victims forced to bear litigation costs to undo deliberate wrongdoing.” (ECF No. 349 at PageID 5865.) And it relies on four cases to support its position that its “entitlement to attorneys’ fees is

2 Even if it did prevail on a contract claim, OJC has not argued that a contract entitles it to attorneys’ fees. incontrovertible” because it “prevailed on the core fraud claims.” (Id. at PageID 5876–77.) See In re Schmank, 535 B.R. 243, 267 (Bankr. E.D. Tenn. 2015) (“[U]nder Tennessee law related to damages arising from misrepresentation, the Plaintiffs are entitled to attorney fees.”); Ellis v. Duggan, 644 S.W.3d 85, 127 (Tenn. Ct. App. 2021) (“We noted that awards of attorney fees have been upheld based on findings of fraud[.]”); Francis v. Barnes, No. W2012-02316-COA-

R3-CV, 2013 WL 5372851, at *11 (Tenn. Ct. App. Sept. 23, 2013) (“Here, the trial court’s award of attorney’s fees to Mrs. Francis is authorized as a recoverable pecuniary loss resulting from the Barneses’ intentional misrepresentations.”); Lewis v. Lewis, No. E2014-00105-COA- R3-CV, 2015 WL 1894267, at *12 (Tenn. Ct. App. Apr. 27, 2015) (“We have upheld an award of attorney’s fees based on a finding of intentional misrepresentation.”). The Court finds that OJC is mistaken. As HYC correctly points out, three of the cases OJC cites address defendants who, used a confidential relationship to defraud individuals of diminished mental capacity. Ellis, 644 S.W.3d at 128–29 (quoting Martin v. Moore, 109 S.W.3d 305, 313 (Tenn. Ct. App. 2003) (“[T]he imposition of [attorney] fees on fiduciaries who

deliberately use their position of trust to enrich themselves creates a disincentive to such behavior.”)); Francis, 2013 WL 5372851, at *11 (awarding attorneys’ fees for intentional misrepresentation claim where a decedent’s grandsons exercised undue influence over her to obtain her property deed); Lewis, 2015 WL 1894267, at *14 (“Under Martin and the cases cited therein, the trial court was supported in awarding attorney’s fees against Sam Lewis on the ground of his abuse of his fiduciary duty by deliberately using his position of trust to enrich himself at the expense of his ward, Dorothy Lewis.”). And in the other case, a bankruptcy court applying Tennessee law awarded attorneys’ fees for a “breach of fiduciary duty by misrepresentation.” In re Schmank, 535 B.R. at 267 (citing Martin, 109 S.W.3d at 313).

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245 S.W.3d 372 (Tennessee Supreme Court, 2008)
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109 S.W.3d 305 (Court of Appeals of Tennessee, 2003)
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703 S.W.2d 133 (Tennessee Supreme Court, 1986)
Connors v. Connors
594 S.W.2d 672 (Tennessee Supreme Court, 1980)
Keith v. Howerton
165 S.W.3d 248 (Court of Appeals of Tennessee, 2004)
Pullman Standard, Inc. v. Abex Corp.
693 S.W.2d 336 (Tennessee Supreme Court, 1985)
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124 S.W.3d 541 (Court of Appeals of Tennessee, 2003)
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HYC LOGISTICS INC. v. OJCOMMERCE, LLC, doing business as OJ Commerce, LLC, and JACOB WEISS, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hyc-logistics-inc-v-ojcommerce-llc-doing-business-as-oj-commerce-llc-tnwd-2025.