Preciado v. Recon Security Corp.

CourtDistrict Court, W.D. Texas
DecidedAugust 13, 2025
Docket3:23-cv-00052
StatusUnknown

This text of Preciado v. Recon Security Corp. (Preciado v. Recon Security Corp.) 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
Preciado v. Recon Security Corp., (W.D. Tex. 2025).

Opinion

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

JOSE PRECIADO, § Plaintiff, § § v. § EP-23-CV-00052-RFC § RECON SECURITY CORP., § Defendant. §

MEMORANDUM OPINION AND ORDER

Before the Court is Plaintiff Jose Preciado’s “Motion for Sanctions, Entry of Default, and Default Judgment” (“Default Judgment Motion”) (ECF No. 78) and “Motion for Attorney Fees and Costs” (“Attorney Fee Motion”) (ECF No. 79). For the reasons set forth below, the Court GRANTS the Default Judgment Motion. The Court GRANTS the Attorney Fee Motion in part and DENIES it in part. I. BACKGROUND Plaintiff filed suit against Defendant Recon Security Corp. on February 6, 2023. See Pl.’s Original Compl. & Jury Demand, ECF No. 1. Plaintiff accused Defendant of failing to pay overtime as required under the Fair Labor Standards Act (“FLSA”). Id. ¶ 47. Plaintiff subsequently amended his complaint and also accused Defendant of sexual harassment and retaliation. Pl.’s Am. Compl. & Jury Demand ¶¶ 65–66 [hereinafter Am. Compl.], ECF No. 7. Plaintiff and Defendant both filed motions for summary judgment. See Def.’s Mot. Summ. J., ECF No. 21; Pl.’s Traditional Mot. Partial Summ. J., ECF No. 23. The Court denied Plaintiff’s motion and partially granted Defendant’s motion, dismissing Plaintiff’s claims for sexual harassment and retaliation. Mem. Op. & Order 29–30, ECF No. 39. On April 11, 2025, Defendant’s attorney filed a motion to withdraw as counsel. See Mot. Withdraw Attorney Record, ECF No. 67. He stated in the motion that Defendant no longer had the resources to continue employing him and requested that he withdraw. Id. at 2. Defendant’s counsel filed a notice with the Court that he had warned Defendant that he might face a default judgment for failure to defend the case. Counsel’s Certification Notice Defendant Withdrawal

Representation & Future Events 1, ECF No. 70. After a hearing, the Court granted the motion to withdraw and gave Defendant 30 days to find new counsel. Order 2, ECF No. 71. Defendant was warned that failure to find new counsel could lead to a default judgment being imposed. Id. This order was sent to Defendant via certified mail. See Certified Mail Receipt, ECF No. 75. As a corporation, Defendant must be represented by counsel. In re K.M.A., Inc., 652 F.2d 398, 399 (5th Cir. Unit B July 1981). Defendant did not find new counsel during this 30-day period. The Court set a status conference for June 30, 2025, and ordered Defendant and its new counsel to be present. See Order

Setting Status Conference, ECF No. 73. This order was sent via certified mail to Defendant. See Certified Mailing, ECF No. 74. Again, Defendant was warned that failure to appear could lead to a default judgment being imposed. Order Setting Status Conference 1. Neither Defendant nor any counsel appeared at the status conference. Subsequently, Plaintiff filed the two current motions on July 11, 2025. See Default J. Mot., ECF No. 78; Att’y Fee Mot., ECF No. 79. The Court set a hearing on damages for July 21, 2025, and again ordered Defendant to appear. See Order Setting Hearing, ECF No. 80. This order was sent to Defendant via certified mail. See Certified Mailing, ECF No. 81. Defendant did not put in an appearance. The Court heard Plaintiff’s testimony as to damages and now issues the following

opinion. II. STANDARD A. Default Judgment 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 or otherwise defend the case. 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.”). 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). The court may conduct a hearing on a default judgment motion, as needed, 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. 55(b)(2). A hearing on damages is required “unless the amount

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