Jones v. Richmond County Sheriff Department

CourtDistrict Court, S.D. Georgia
DecidedMay 12, 2025
Docket1:23-cv-00160
StatusUnknown

This text of Jones v. Richmond County Sheriff Department (Jones v. Richmond County Sheriff Department) is published on Counsel Stack Legal Research, covering District Court, S.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jones v. Richmond County Sheriff Department, (S.D. Ga. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF GEORGIA

AUGUSTA DIVISION

CHRISTOPHER F. JONES, ) ) Plaintiff, ) ) v. ) CV 123-160 ) DR. HAWES, ) ) Defendant. )

MAGISTRATE JUDGE’S REPORT AND RECOMMENDATION

Plaintiff, currently incarcerated at U.S. Penitentiary Lee in Jonesville, Virginia, filed this case pursuant to 42 U.S.C. § 1983, concerning events alleged to have occurred at Charles B. Webster Detention Center (“CBWDC”) in Augusta, Georgia. Before the Court is Defendant’s motion to set aside entry of default, (doc. no. 46), and Plaintiff’s motion for default judgment, (doc. no. 50). For the reasons set forth below, the Court REPORTS and RECOMMENDS Defendant’s motion to set aside entry of default be GRANTED, (doc. no. 46), Plaintiff’s motion for default judgment be DENIED, (doc. no. 50), and Defendant’s Motion in Opposition to Plaintiff’s motion be DENIED AS MOOT, (doc. no. 51). I. BACKGROUND On April 23, 2024, the Court allowed Plaintiff’s medical deliberate indifference claim against Defendant Hawes to proceed. (Doc. no. 22; see also doc. no. 33.) After several months of service attempts, (see, e.g., doc. nos. 22, 33, 35, 36, 37, 39), including successful completion of personal service by the U.S. Marshal, (doc. no. 39), Defendant did not timely file an answer or otherwise appear in the case. Accordingly, on November 5, 2024, the Court ordered Defendant to show cause why the Clerk of Court should not enter default against her pursuant to Fed. R. Civ. P. 55(b), and ordered service of various filings on Wellpath, Defendant’s former employer, to ensure it was aware of this suit. (Doc. no. 40.) When the time to comply with

the Court’s November 5th Order passed, and neither Defendant nor any representative of Wellpath appeared in this case, filed an answer, or otherwise responded to the Court’s November 5th Order, the Court directed entry of default against Defendant on January 10, 2025, and served copies of the Order on Wellpath. (Doc. no. 43.) On January 24, 2025, attorney Robin Daitch1 filed an answer and motion to set aside entry of default on behalf of Defendant, (doc. nos. 45, 46), as well as a Suggestion of Bankruptcy and Stay indicating Wellpath was undergoing Chapter 11 Bankruptcy proceedings in the Southern District of Texas.2 In her motion, Defendant argues her default was neither

culpable nor willful. (Doc. no. 46.) She explains she was a Wellpath employee at the time of the events described in Plaintiff’s amended complaint, and as such, “relied on Wellpath to provide representation and a defense.” (Id. at 4.) However, “Wellpath had recently filed bankruptcy and was attempting to deal with financial obligations and debts across the country,

1 Defense counsel’s motion to withdraw as counsel of record pending before the presiding District Judge need not delay the resolution of the issues discussed herein. Should a stay be warranted while Defendant identifies substitute counsel, she may move for such relief.

2 According to the Suggestion of Bankruptcy, an automatic stay was imposed on all lawsuits in which a Wellpath employee or former employee who may be subject to indemnification obligations is named as a defendant. (See doc. no. 47.) However, because this stay has expired as of April 30, 2025, the ongoing bankruptcy proceedings need not delay the Court’s resolution of the issues addressed herein. (See id. at 52 (“[T]he Lawsuits are stayed until the earlier of (a) the effective date of a confirmed chapter 11 plan; (b) dismissal of the chapter 11 cases of the Debtors; or (c) April 30, 2025.” (emphasis added)).) Should the Bankruptcy Court further extend the stay of lawsuits involving former Wellpath employees, Defendant may file a renewed Suggestion of Bankruptcy and Motion to Stay this case for the presiding District Judge’s consideration. and in the process, whether through inadvertence, oversight, or mistake, had failed to provide a timely defense.” (Id.) Defendant further asserts Plaintiff would not be prejudiced by opening default, she presents a meritorious defense in her proposed Answer, and default poses a significant financial threat to Defendant. (Id. at 4-5.)

On January 30, 2025, the Court received Plaintiff’s motion for default judgment in accordance with Federal Rule of Civil Procedure 55. (Doc. no. 50.) Defendant filed a response in opposition to Plaintiff’s declaration styled as a “Motion Opposing Plaintiff’s Motion to Seek Default Judgment,” citing the same arguments made in her motion to set aside. (See doc. no. 51.)3 Plaintiff responded in opposition to Defendant’s motions. (Doc. nos. 52, 53.) II. DISCUSSION Rule 55(c) of the Federal Rules of Civil Procedure states that “[f]or good cause shown the court may set aside an entry of default.” Fed. R. Civ. P. 55(c). It is the defaulting party’s

burden to establish good cause. Sherrard v. Macy’s Sys. & Tech. Inc., 724 F. App’x 736, 738 (11th Cir. 2018) (per curiam). The Eleventh Circuit has expressed the “good cause” standard should be interpreted liberally. Compania Interamericana Export-Import, S.A. v. Compania Dominicana De Aviacion, 88 F.3d 948, 951 (11th Cir. 1996). Although “‘good cause’ is not susceptible to a precise formula,” there are several factors that may aid in its determination. Id. These factors include but are not limited to: (1) whether the default was culpable or willful;

(2) whether setting default aside would prejudice the adversary; (3) whether the defaulting party presents a meritorious defense; and (4) whether the defaulting party acted promptly to correct the default. Id. While the factors considered may vary from case to case, the

3 Because Defendant’s motion is properly construed as a response and should not have been styled as a “Motion in Opposition” because it seeks no new form of relief or Court action, it should be DENIED AS MOOT. (Id.) overarching policy disfavoring default judgments should always be considered. See Mitchell v. Brown & Williamson Tobacco Corp., 294 F.3d 1309, 1316-17 (11th Cir. 2002) (cautioning default is a drastic remedy that should be used sparingly and only in extreme situations); Fla.

Physician’s Ins. Co. v. Ehlers, 8 F.3d 780, 783 (11th Cir. 1993) (“[D]efaults are seen with disfavor because of the strong policy of determining cases on their merits.”). The Court finds Defendant has established good cause to set aside an entry of default against her. In considering the above factors, Defendant asserts she relied on her former employer, Wellpath, to provide representation, but Wellpath failed to provide a timely defense on Plaintiff’s behalf amid bankruptcy proceedings with nationwide implications. (Doc. no. 46.) While Defendant’s lack of action to confirm representation by Wellpath may be negligent,

it cannot be described as culpable or a pattern of willful delay. Perez v. Wells Fargo N.A., 774 F.3d 1329, 1339 (11th Cir.

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Jones v. Richmond County Sheriff Department, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jones-v-richmond-county-sheriff-department-gasd-2025.