Joe Hand Promotions, Inc. v. City Slickers Limited Liability Company

CourtDistrict Court, W.D. Texas
DecidedMay 2, 2025
Docket3:24-cv-00214
StatusUnknown

This text of Joe Hand Promotions, Inc. v. City Slickers Limited Liability Company (Joe Hand Promotions, Inc. v. City Slickers Limited Liability Company) is published on Counsel Stack Legal Research, covering District Court, W.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Joe Hand Promotions, Inc. v. City Slickers Limited Liability Company, (W.D. Tex. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS EL PASO DIVISION

JOE HAND PROMOTIONS, INC., § § Plaintiff, § § v. § § EP-24-CV-00214-KC CITY SLICKERS LIMITED §

LIABILITY COMPANY and KENNETH § O. EKECHUKWU, § § Defendants. §

REPORT AND RECOMMENDATION

Before the Court is Plaintiff Joe Hand Promotions, Inc.’s “Motion for Final Default Judgment and Supporting Brief” (“Motion”) (ECF No. 11), filed on October 24, 2024. United States District Judge Kathleen Cardone referred the motion to the undersigned Magistrate Judge for a report and recommendation pursuant to 28 U.S.C. § 636(b)(1)(B) and Rule 1(d) of Appendix C to the Local Rules of the Western District of Texas. For the reasons set forth below, the Court RECOMMENDS that Plaintiff’s Motion for Default Judgment be GRANTED in part and DENIED in part. I. BACKGROUND Plaintiff had the exclusive commercial license to distribute the July 10, 2021, broadcast of the Ultimate Fighting Championship® 264: Dustin Poirier vs. Conor McGregor 3 mixed martial arts match, including the preliminary bouts and commentary (collectively, the “Event”). Compl. ¶ 3, ECF No. 1. Defendant City Slickers Limited Liability Company is a Texas limited liability company that did business as AXO Rock Kitchen & Lounge (the “Establishment”) on the date of the program. Id. ¶ 4. Defendant Kenneth O. Ekechukwu is the registered agent of City Slickers Limited Liability Company and “operated, maintained, and controlled” the Establishment. Id. ¶ 5; see also Mot. Ex. A, at 4, ECF No. 11-1. Defendants had the ability to legally broadcast the Event after paying a commercial sublicense fee to Plaintiff but did not do so. Compl. ¶ 9. Defendants managed to intercept the transmission of the Event and allowed patrons at the Establishment to view the Event. Id. One of Plaintiff’s auditors entered the Establishment and observed the Event

being broadcast on a television within. Mot. Ex. B(3), at 1, ECF No. 11-5. On June 19, 2024, Plaintiff filed suit against Defendants, alleging that they violated the Federal Communications Act (“FCA”), 47 U.S.C. §§ 553 and 605. See Compl. Both Defendants were served. See Affs. Service, ECF Nos. 6, 7. Defendants had twenty-one days from service to answer. Fed. R. Civ. P. 12(a)(1)(A)(i). They did not timely answer. Plaintiff filed a request for entries of default against Defendants on September 27, 2024. See Pl.’s Req. Clerk’s Entry Default Against Defs., ECF No. 8. Entry of default against Defendants was granted on October 1, 2024. See Default by Clerk, ECF No. 9. Plaintiff then filed the instant motion. Defendants have not

responded to the motion for default judgment or otherwise appeared in this matter. II. STANDARD Federal Rule of Civil Procedure 55 governs entry of default and default judgment. In ruling on a motion for default judgment, courts generally analyze the following three issues: (1) the procedural propriety of default judgment, (2) the substantive merits of the plaintiff’s claims, and (3) the appropriate form of relief. United States v. 1998 Freightliner Vin #: 1FUYCZYB3WP886986, 548 F. Supp. 2d 381, 384 (W.D. Tex. 2008); J&J Sports Prods., Inc. v. Morelia Mexican Rest., Inc., 126 F. Supp. 3d 809, 813–14 (N.D. Tex. 2015). Procedurally, a defendant defaults if he or she fails to timely respond to the complaint. Fed.

R. Civ. P. 55(a); N.Y. Life Ins. Co. v. Brown, 84 F.3d 137, 141 (5th Cir. 1996). When default is shown “by affidavit or otherwise,” the clerk of the court “must enter the party’s default.” Fed. R. Civ. P. 55(a). After entry of default, the plaintiff may seek an entry of default judgment. Id. 55(b). Default judgment is “a drastic remedy, not favored by the Federal Rules and resorted to by courts only in extreme situations.” Sun Bank of Ocala v. Pelican Homestead and Sav. Ass’n, 874 F.2d 274, 276 (5th Cir. 1989) (footnote omitted). In deciding whether default judgment is procedurally

proper, the court considers the following factors: [1] whether material issues of fact are at issue, [2] whether there has been substantial prejudice, [3] whether the grounds for default are clearly established, [4] whether the default was caused by a good faith mistake or excusable neglect, [5] the harshness of a default judgment, and [6] whether 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) (“Lindsey factors”). Next, as to the merits of a motion for default judgment, the court accepts the plaintiff’s well-pleaded allegations as true, except regarding damages. Nishimatsu Constr. Co. v. Hous. Nat’l Bank, 515 F.2d 1200, 1206 (5th Cir. 1975); U.S. for Use of M-CO Const., Inc. v. Shipco Gen., Inc., 814 F.2d 1011, 1014 (5th Cir. 1987). Default judgment is appropriate only if the pleadings provide a “sufficient basis” for the judgment. Nishimatsu, 515 F.2d at 1206. In other words, “a defendant’s default does not in itself warrant the court in entering a default judgment. . . . The defendant is not held to admit facts that are not well-pleaded or to admit conclusions of law.” Id. Courts apply the Federal Rule of Civil Procedure 8 standard1 for the sufficient basis inquiry. Wooten v. McDonald Transit Assocs., Inc., 788 F.3d 490, 498 (5th Cir. 2015); see also id. n.3 (“Although most cases addressing Rule 8 arise in the context of a Rule 12(b)(6) motion to dismiss, . . . we decline to import Rule 12 standards into the default-judgment context.”).

1 Rule 8 requires only “a short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). However, the allegations “must be enough to raise a right to relief above the speculative level.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007). Finally, as to the appropriate form of relief, “[a] default judgment must not differ in kind from, or exceed in amount, what is demanded in the pleadings.” Fed. R. Civ. P. 54(c).

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Joe Hand Promotions, Inc. v. City Slickers Limited Liability Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/joe-hand-promotions-inc-v-city-slickers-limited-liability-company-txwd-2025.