Peak Property & Casualty Insurance Corporation v. Sevilla

CourtDistrict Court, S.D. Alabama
DecidedJuly 1, 2025
Docket1:23-cv-00117
StatusUnknown

This text of Peak Property & Casualty Insurance Corporation v. Sevilla (Peak Property & Casualty Insurance Corporation v. Sevilla) is published on Counsel Stack Legal Research, covering District Court, S.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Peak Property & Casualty Insurance Corporation v. Sevilla, (S.D. Ala. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION

PEAK PROPERTY AND CASUALTY ) INSURANCE CORP., ) ) Plaintiff, ) ) v. ) CIV. ACT. NO. 1:23-cv-117-TFM-MU ) MARIA SEVILLA, et al. ) ) Defendants. )

MEMORANDUM OPINION AND DEFAULT JUDGMENT Pending before the Court is Plaintiff’s Motion for Default Judgment (Doc. 77, filed 5/15/25) against Defendant Maria Sevilla. For the reasons stated below, the motion is GRANTED. Rule 55 of the Federal Rules of Civil Procedure provides the mechanism for default judgments. Specifically, Rule 55 establishes a two-part process for obtaining a default judgment. First, “[w]hen a party against whom a judgment for affirmative relief is sought has failed to plead or otherwise defend and that failure is shown by affidavit or otherwise, the clerk [of court] must enter the party’s default.” FED. R. CIV. P. 55(a). After default has been entered, if the “claim is for a sum certain or a sum that can be made certain by computation,” the clerk must enter default judgment. FED. R. CIV. P. 55(b)(1). “In all other cases, the party must apply to the court for a default judgment.” FED. R. CIV. P. 55(b)(2). Once a party applies for a default judgment, “[t]he court may conduct hearings or make referrals . . . when, to enter or effectuate judgment, it needs to: (A) conduct an accounting; (B) determine the amount of damages; (C) establish the truth of any allegation by evidence; or (D) investigate any other matter.” Id. Accordingly, simply because a defendant is in default under Rule 55(a) does not mean the plaintiff is automatically entitled to a default judgment under Rule 55(b). See generally 10A Charles Alan Wright, Arthur R. Miller, & Mary Kay Kane, Federal Practice & Procedure § 2685 (4th ed. 2016). Additionally, in this Circuit, “there is a strong policy of determining cases on their merits and we therefore view defaults with disfavor.” In re Worldwide Web Sys., Inc., 328 F.3d 1291, 1295 (11th Cir. 2003); see also Surtain v. Hamlin Terrace Found., 789 F.3d 1239, 1244-45 (11th Cir. 2015) (quoting Worldwide Web Sys. and holding same). The Eleventh Circuit states default judgments are “a drastic remedy that should

be used sparingly and only in extreme situations where no other forms of relief are available.” Graveling v. Castle Mortg. Co., 631 F. App’x 690, 698 (11th Cir. 2015) (quoting Mitchell v. Brown & Williamson Tobacco Corp., 294 F.3d 1309, 1316-17 (11th Cir. 2002) (internal quotations omitted). While the entry of default is a necessary condition for obtaining a default judgment, it is not sufficient. “[A] default is not treated as an absolute confession by the defendant of his liability and of the plaintiff’s right to recover,” but instead “a defaulted defendant is deemed to ‘admit[] the plaintiff's well-pleaded allegations of fact.’” Tyco Fire & Sec., LLC v. Alcocer, 218 F. App’x 860, 863 (11th Cir. 2007) (quoting Nishimatsu Constr. Co. v. Houston Nat’l Bank, 515 F.2d 1200, 1206

(5th Cir. 1975)). Rule 55(b)(1) permits entry of judgment by the clerk without a hearing in cases where “the plaintiff’s claim is for a sum certain or a sum that can be made certain by computation.” FED. R. CIV. P. 55(b)(1). In all other cases, the Court “may conduct hearings” to “conduct an accounting,” “determine the amount of damages,” “establish the truth of any allegation by evidence,” or “investigate any other matter.” FED. R. CIV. P. 55(b)(2)(A)-(D). Though the language indicates a hearing is not a “per se requirement,” Eleventh Circuit precedent indicates that evidentiary hearings “are required in all but limited circumstances.” SEC v. Smythe, 420 F.3d 1225, 1231-32 n. 13 (11th Cir. 2005); see also Safari Programs, Inc. v. CollectA Int’l Ltd., 686 F. App’x 737, 746- 47 (11th Cir. 2017) (citing Rule and Smythe). After default was entered and the motion for default judgment filed, the Court set a virtual hearing and notified the Defendant Maria Sevilla of the hearing date and her deadline to respond to the motion. See Doc. 78. The Court also warned the Defendant Maria Sevilla that failure to respond and/or appear could constitute a waiver of her rights to defend themselves in this lawsuit.

See id. Heedless of the warning, Defendant Maria Sevilla failed to respond or attend the hearing on June 24, 2025 despite seeming having received a copy of the order on May 27, 2025. See Doc. 79. Therefore, having reviewed the complaint, the motion for default judgment, the memorandum in support of the motion, and the exhibits attached thereto, and in consideration of the entire record herein, this Court finds the following: 1. Plaintiff issued an Alabama personal auto policy to Maria Sevilla, Policy Number 11406778587, with a policy period from December 14, 2021 to December 14, 2022, (the “Policy”). The Policy provided insurance coverage to one driver, Maria Sevilla, and one covered auto: a 2008

Nissan/Datsun Armada SE/LE. Doc. 77-3. 2. On February 12, 2021, Maria Sevilla signed a Named Driver Exclusion Endorsement explicitly excluding coverage to vehicles operated by Defendants Jose Caracamo and Juana Sevilla. Doc. 77-4. This exclusion was in effect at the time of the accident on April 3, 2022. 3. The Policy states: Notice of Car Accident or Loss In the event of a car accident or loss, prompt notice must be given to us. This must include the time, please and facts of the car accident or loss. Your name, address, the best way to contact you and any involved persons and witnesses must be provided. The information which you give to us must be truthful and accurate. Other Duties

Any person claiming coverage under this policy must:

(1) Cooperate and assist us in any matter regarding a claim or lawsuit.

. . .

(5) Submit separately to recorded statements and exams under oath. Provide sworn statements. This must be done as often as we reasonably required.

Failure to perform or comply with any of these duties may result in the refusal of coverage, protection or a reduced loss payment.

Doc. 77-3.

4. On April 3, 2022, a 2009 GMC Sierra vehicle owned by Patricia Juana Sevilla and operated by Jose Caracamo was involved in an eight-vehicle accident on U.S. Highway 331 in Walton County, Florida. Doc. 77-1. The crash resulted in several injuries and a fatality. Id. 5. Jose Caracamo and Juana Sevilla are listed as “excluded drivers” on the Policy and the GMC Sierra involved in the crash is not listed as a covered vehicle under the Policy. Doc. 77- 3. 6. On May 27, 2022, counsel for Plaintiff sent a letter by certified mail and email to Maria Sevilla’s known addresses, requesting that she contact counsel for Plaintiff to schedule an examination under oath, pursuant to her duty to cooperate under the terms of the Policy. Doc. 77- 5. 7. After receiving no response to the first letter, counsel for Plaintiff mailed and emailed a second letter to the insured, Maria Sevilla, on July 25, 2022 scheduling her examination under oath for August 10, 2022. Doc. 77-6. 8. Maria Sevilla did not appear for her scheduled examination under oath on August 10, 2022. 9.

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Related

Tyco Fire & Security LLC v.Jesus Hernandez Alcocer
218 F. App'x 860 (Eleventh Circuit, 2007)
William Mitchell v. Phillip Morris Incorporated
294 F.3d 1309 (Eleventh Circuit, 2002)
Securities & Exchange Commission v. Smyth
420 F.3d 1225 (Eleventh Circuit, 2005)
Portia Surtain v. Hamlin Terrace Foundation
789 F.3d 1239 (Eleventh Circuit, 2015)
Irina Giovanno v. Louis Fabec
804 F.3d 1361 (Eleventh Circuit, 2015)
James Graveling v. Bank United N.A.
631 F. App'x 690 (Eleventh Circuit, 2015)
United States v. Bains
686 F. App'x 737 (Eleventh Circuit, 2017)

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Bluebook (online)
Peak Property & Casualty Insurance Corporation v. Sevilla, Counsel Stack Legal Research, https://law.counselstack.com/opinion/peak-property-casualty-insurance-corporation-v-sevilla-alsd-2025.