JBS Packerland, Inc. v. Phillips Cattle Co., Inc.

CourtDistrict Court, S.D. California
DecidedFebruary 24, 2025
Docket3:24-cv-01299
StatusUnknown

This text of JBS Packerland, Inc. v. Phillips Cattle Co., Inc. (JBS Packerland, Inc. v. Phillips Cattle Co., Inc.) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
JBS Packerland, Inc. v. Phillips Cattle Co., Inc., (S.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 JBS PACKERLAND, INC., Case No. 24-cv-01299-BAS-MSB 12 Plaintiff, ORDER: 13 v.

14 (1) GRANTING MOTION TO SEAL (ECF No. 19); AND 15 PHILLIPS CATTLE CO., INC.,

16 Defendant. (2) GRANTING MOTION FOR DEFAULT JUDGMENT AND 17 REQUEST FOR ATTORNEYS’ FEES 18 AND COSTS (ECF No. 21)

20 21 22 This is a breach of contract case arising in the meat processing industry, specifically 23 concerning futures contracts for the purchase and delivery of Holstein steers across the 24 United States. Before the Court are Plaintiff JBS Packerland, Inc.’s (“JBS”) Motion for 25 Default Judgment and Request for Attorneys’ Fees and Costs (“Motion for Default 26 Judgment”) against Defendant Phillips Cattle Co., Inc. (“Phillips Cattle”) (ECF No. 21) 27 and Motion to Seal (ECF No. 19). The Court finds the Motions suitable for determination 28 1 on the papers submitted and without oral argument. See Fed. R. Civ. P. 78(b); CivLR 2 7.1(d)(1). For the reasons set forth below, Plaintiff’s Motions are GRANTED. 3 I. BACKGROUND 4 JBS Packerland, Inc., a Delaware corporation with its principal place of business in 5 Colorado, operates in the meat processing industry and executes futures contracts with 6 various suppliers for the purchase and delivery of Holstein steers across the United States. 7 (Compl. ¶ 1, ECF No. 1; Loewe Decl. ¶ 3.) On June 23, 2022, JBS entered into six separate 8 futures contracts with Phillips Cattle, a California corporation, for the purchase and 9 delivery of Holstein steers. (Compl. ¶ 6; Loewe Decl. ¶ 5.) These contracts were 10 negotiated and executed in California, where Phillips Cattle is based, and the steers were 11 to be delivered from California. (Loewe Decl. ¶¶ 5, 7.) 12 Phillips Cattle failed to deliver the contracted quantities of Holstein steers as 13 required under the agreements. (Id. ¶ 8.) Specifically, the contracts required delivery of a 14 specified weight of Holstein steers in March and April 2023, but Phillips Cattle did not 15 fulfill these obligations, resulting in a significant shortfall. (Compl. ¶ 13; Loewe Decl. ¶ 16 15.) As a result, JBS incurred additional costs to cover the shortfall by purchasing 17 replacement steers at a higher premium than originally contracted. (Compl. ¶ 18.) The 18 contracts also included indemnification provisions obligating Phillips Cattle to cover any 19 losses arising from breaches, including attorneys’ fees and costs. (Id. ¶ 17.) 20 Despite attempts by JBS to resolve the issue amicably, Phillips Cattle did not 21 respond to communications or honor its indemnification obligations. (Loewe Decl. ¶ 17.) 22 Consequently, JBS brought this action against Phillips Cattle for breach of contract, 23 indemnification, and unjust enrichment on July 25, 2024, and requested attorneys’ fees and 24 costs pursuant to the terms of Section 4 of each contract. (Compl. ¶ 17, Prayer for Relief 25 ¶ 3.) Phillips Cattle was duly served with the Summons and Complaint on August 25, 26 2024. (ECF No. 11.) Phillips Cattle failed to answer or otherwise appear in the action, and 27 the Clerk entered default against it on September 24, 2024. (ECF No. 13.) 28 1 On October 24, 2024, JBS filed its Motion for Default Judgment, seeking a total 2 judgment amount of $153,743.11, which includes $31,720.00 in attorneys’ fees and 3 $2,354.87 in costs, along with pre- and post-judgment interest. (ECF No. 21-1 at 14:4–8.) 4 Concurrently, JBS filed its Motion to Seal the Motion for Default Judgment, along with 5 the supporting Memorandum of Points and Authorities and Declaration of J.T. Loewe. 6 (ECF No. 19.) 7 II. LEGAL STANDARD 8 Rule 55(b)(2) of the Federal Rules of Civil Procedure governs applications to the 9 court for default judgment. Entry of default judgment is within the trial court’s discretion. 10 See Taylor Made Golf Co. v. Carsten Sports, Ltd., 175 F.R.D. 658, 660 (S.D. Cal. 1997) 11 (citing Lau Ah Yew v. Dulles, 236 F.2d 415, 416 (9th Cir. 1956)). In making this 12 determination, the court considers the following factors: (1) the possibility of prejudice to 13 the plaintiff; (2) the merits of plaintiff’s substantive claim; (3) the sufficiency of the 14 complaint; (4) the sum of money at stake in the action; (5) the possibility of a dispute 15 concerning the material facts; (6) whether the default was due to excusable neglect; and 16 (7) the strong policy underlying the Federal Rules of Civil Procedure favoring decisions 17 on the merits (collectively, “Eitel factors”). See Eitel v. McCool, 782 F.2d 1470, 1471–72 18 (9th Cir. 1986). 19 Upon entry of default, the factual allegations in plaintiff’s complaint, except those 20 relating to damages, are deemed admitted. TeleVideo Sys., Inc. v. Heidenthal, 826 F.2d 21 915, 917–18 (9th Cir. 1987). 22 III. ANALYSIS 23 As an initial matter, Plaintiff has met the first step of the two-step process for 24 obtaining default judgment. Pursuant to Rule 55(a), the Clerk of the Court correctly 25 entered default against Defendant because it has not appeared in the case. (ECF No. 13.) 26 Thus, in its discretion, the Court may order default judgment after confirming jurisdiction, 27 adequacy of service of process, and balancing the Eitel factors. 28 1 A. Jurisdiction & Service of Process 2 When ruling on a motion for default judgment, “a district court has an affirmative 3 duty to look into its jurisdiction over both the subject matter and the parties” given that “[a] 4 judgment entered without personal jurisdiction over the parties is void.” In re Tuli, 172 5 F.3d 707, 712 (9th Cir. 1999). Thus, “[t]o avoid entering a default judgment that can later 6 be successfully attacked as void, a court should determine whether it has the power, i.e., 7 the jurisdiction, to enter the judgment in the first place.” Id.; see also Facebook, Inc. v. 8 Pedersen, 868 F. Supp. 2d 953, 961 (N.D. Cal. 2012) (recommending the district judge 9 “deny Facebook’s motion for default judgment and . . . dismiss this action for lack of 10 personal jurisdiction”). “The Court is also required to assess the adequacy of the service 11 of process on the party against whom default is requested.” DFSB Kollective Co. v. 12 Bourne, 897 F. Supp. 2d 871, 877 (N.D. Cal. 2012) (citation omitted). 13 Federal subject-matter jurisdiction may exist due to the presence of a federal 14 question, see 28 U.S.C. § 1331, or complete diversity between the parties, see 28 U.S.C. § 15 1332. Under federal law, “[t]he district courts shall have original jurisdiction of all civil 16 actions where the amount in controversy exceeds the sum or value of $75,000, exclusive 17 of interest and costs, and is between . . . citizens of different states.” Id. § 1332(a). Here, 18 Plaintiff is seeking a total judgment amount of $153,743.11. (ECF No. 21-1 at 14:4–8.) 19 This amount satisfies the minimum amount in controversy necessary to invoke diversity 20 jurisdiction under 28 U.S.C. § 1332. 21 Furthermore, the Court finds there is also complete diversity among the parties.

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JBS Packerland, Inc. v. Phillips Cattle Co., Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/jbs-packerland-inc-v-phillips-cattle-co-inc-casd-2025.