McLaughlin Group, Inc. v. American Manufacturing & Machine, Inc.

CourtDistrict Court, D. Colorado
DecidedSeptember 11, 2025
Docket1:20-cv-03531
StatusUnknown

This text of McLaughlin Group, Inc. v. American Manufacturing & Machine, Inc. (McLaughlin Group, Inc. v. American Manufacturing & Machine, Inc.) is published on Counsel Stack Legal Research, covering District Court, D. Colorado primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
McLaughlin Group, Inc. v. American Manufacturing & Machine, Inc., (D. Colo. 2025).

Opinion

\IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Chief Judge Philip A. Brimmer

Civil Action No. 20-cv-03531-PAB-TPO

MCLAUGHLIN GROUP, INC., a South Carolina Corporation, and VAC-TRON EQUIPMENT, LLC, a Delaware limited liability company

Plaintiffs,

v.

AMERICAN MANUFACTURING & MACHINE, INC., a Florida corporation,

Defendant.

ORDER

This matter comes before the Court on Plaintiffs’ Renewed Motion for Default Judgment [Docket No. 162] and defendant American Manufacturing & Machine, Inc.’s Motion to Dismiss Due to Egregious Deception by the Plaintiffs [Docket No. 167]. American Manufacturing & Machine, Inc. (“AMM”), purportedly appears through two staff members of AMM, filed a response to the motion for default judgment. Docket No. 163.1 Plaintiffs McLaughlin Group, Inc. (“McLaughlin”) and Vac-Tron Equipment, LLC (“Vac-Tron”) filed a reply to the motion for default judgment. Docket No. 165. Plaintiffs filed a response to AMM’s motion to dismiss, Docket No. 168, and AMM filed an

1 The Court will not consider this response because a corporate entity may not appear pro se in federal court. See Docket No. 166 at 1-2. unsigned reply. Docket No. 169.2 The Court has jurisdiction pursuant to 28 U.S.C. § 1332. I. BACKGROUND This case has a lengthy procedural history. The Court recounted the key portions of that history in its August 16, 2024 order. See Docket No. 161 at 1-2. The

Court will repeat that history here along with the subsequent developments in the case. Plaintiffs initiated this case by filing a complaint on November 30, 2020. Docket No. 1. They filed an amended complaint on December 22, 2020. Docket No. 17. The amended complaint asserts one claim against defendant American Manufacturing & Machine, Inc., namely, breach of a member interest purchase agreement (“MIPA”). Id. at 3, 18-22, ¶¶ 11, 70-86. On January 29, 2021, attorney Daniel F. Warden appeared on behalf of AMM and filed an answer and counterclaim. Docket No. 46. On July 31, 2023, Mr. Warden filed a motion to withdraw as counsel for AMM. Docket No. 147. On August 18, 2023, then-Magistrate Judge Kato S. Crews granted Mr. Warden’s motion. Docket No. 149. Judge Crews’ order stated that, “because

Defendant is a corporation, Defendant may not appear without counsel admitted to the bar of this Court, and that absent prompt appearance of substitute counsel, pleadings and papers may be stricken, and default judgment or other sanctions may be imposed against Defendant.” Id. No attorney has since filed an appearance on behalf of AMM. Plaintiffs asked the Court to enter default judgment against AMM pursuant to Federal Rules of Civil Procedure 16 and 37. Docket No. 156 at 5, ¶ 17. The Court found that default judgment was an appropriate sanction for AMM’s failure to obtain

2 The Court will not consider this reply because a corporate entity may not appear pro se in federal court. See Docket No. 166 at 1-2. counsel in violation of a Court order, Docket No. 161 at 8, but denied the motion for default judgment because the plaintiffs failed to argue that they were entitled to default judgment based on the facts alleged in the complaint. Id. at 8-9. Plaintiffs subsequently filed a renewed motion for default judgment. Docket No. 162. II. LEGAL STANDARD

A. Sanctions Federal Rule of Civil Procedure 16 permits a court to issue “any just orders” if a party “fails to obey a scheduling or other pretrial order.” Fed. R. Civ. P. 16(f)(1)(C). Available sanctions include “rendering a default judgment against the disobedient party.” Fed. R. Civ. P. 37(b)(2)(A)(vi); see also Klein v. Harper, 777 F.3d 1144, 1147 (10th Cir. 2015) (holding that “courts have broad inherent power to sanction misconduct and abuse of the judicial process, which includes the power to enter a default judgment”) (quotation and citations omitted). When corporations violate orders requiring them to obtain counsel, “[d]istrict courts in this Circuit have entered default judgment as a sanction against non-represented corporate defendants.” Baxter Constr. Co., LLC v. SF Constr., Inc., No. 22-cv-01117-NYW-KLM, 2023 WL 5822502, at *3 (D. Colo. Sept.

8, 2023) (citations omitted). “But before entering default judgment as a sanction, the Court must consider the Ehrenhaus factors to determine whether default judgment is a justified and appropriate sanction.” Id. (citing Ehrenhaus v. Reynolds, 965 F.2d 916, 921 (10th Cir. 1992)). The Ehrenhaus factors are: (1) the degree of actual prejudice to the opposing party, (2) the amount of interference with the judicial process, (3) the culpability of the litigant, (4) whether the court warned the party in advance that dismissal of the action would be a likely sanction for noncompliance, and (5) the efficacy of lesser sanctions. Ehrenhaus, 965 F.2d at 921. B. Default Judgment The decision to enter default judgment is “committed to the district court’s sound discretion.” Olcott v. Del. Flood Co., 327 F.3d 1115, 1124 (10th Cir. 2003) (citation omitted). In exercising that discretion, the Court considers that “[s]trong policies favor resolution of disputes on their merits.” In re Rains, 946 F.2d 731, 732 (10th Cir. 1991)

(quotation and citations omitted). “The default judgment must normally be viewed as available only when the adversary process has been halted because of an essentially unresponsive party.” Id. It serves to protect a plaintiff against “interminable delay and continued uncertainty as to his rights.” Id. at 733. A party may not simply sit out the litigation without consequence. See Cessna Fin. Corp. v. Bielenberg Masonry Contracting, Inc., 715 F.2d 1442, 1444-45 (10th Cir. 1983) (“[A] workable system of justice requires that litigants not be free to appear at their pleasure. We therefore must hold parties and their attorneys to a reasonably high standard of diligence in observing the courts’ rules of procedure. The threat of judgment by default serves as an incentive to meet this standard.”) (citation omitted).

One such consequence is that, upon the entry of default against a defendant, the well- pleaded allegations in the complaint are deemed admitted. See 10A Charles Alan Wright & Arthur R. Miller, Federal Practice & Procedure § 2688.1 (4th ed., 2023 rev.). “Even after default, however, it remains for the court to consider whether the unchallenged facts constitute a legitimate cause of action, since a party in default does not admit conclusions of law.” Id. A court need not accept conclusory allegations. Moffett v. Halliburton Energy Servs., Inc., 291 F.3d 1227, 1232 (10th Cir. 2002). Although “[s]pecific facts are not necessary” in order to state a claim, Erickson v. Pardus, 551 U.S. 89, 93 (2007) (per curiam) (quoting Bell Atl. Corp. v. Twombly, 550 U.S.

Related

Klapprott v. United States
335 U.S. 601 (Supreme Court, 1949)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Moffett v. Halliburton Energy Services, Inc.
291 F.3d 1227 (Tenth Circuit, 2002)
Olcott v. Delaware Flood Co.
327 F.3d 1115 (Tenth Circuit, 2003)
United States v. Craighead
176 F. App'x 922 (Tenth Circuit, 2006)
Bryson v. Gonzales
534 F.3d 1282 (Tenth Circuit, 2008)
Hansen v. GAB Business Services, Inc.
876 P.2d 112 (Colorado Court of Appeals, 1994)
VLIW TECHNOLOGY, LLC v. Hewlett-Packard Co.
840 A.2d 606 (Supreme Court of Delaware, 2003)
Klein v. Harper
777 F.3d 1144 (Tenth Circuit, 2015)
Regional District Council v. Mile High Rodbusters, Inc.
82 F. Supp. 3d 1235 (D. Colorado, 2015)
Jones v. Marquis Properties, LLC
212 F. Supp. 3d 1010 (D. Colorado, 2016)
Herzfeld v. Parker
100 F.R.D. 770 (D. Colorado, 1984)

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Bluebook (online)
McLaughlin Group, Inc. v. American Manufacturing & Machine, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/mclaughlin-group-inc-v-american-manufacturing-machine-inc-cod-2025.