Tratt Industries, LLC v. Patterson

CourtDistrict Court, D. New Mexico
DecidedMarch 27, 2020
Docket1:19-cv-00498
StatusUnknown

This text of Tratt Industries, LLC v. Patterson (Tratt Industries, LLC v. Patterson) is published on Counsel Stack Legal Research, covering District Court, D. New Mexico primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Tratt Industries, LLC v. Patterson, (D.N.M. 2020).

Opinion

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF NEW MEXICO ______________________

TRATT INDUSTRIES, LLC; TROY BAKER; and MATTHEW SHEPARD,

Plaintiffs,

v. Case No. 19-cv-00498-WJ-SCY

DWIGHT L. PATTERSON and LAURIE M. PATTERSON, Individually and as Trustees of the PATTERSON REVOCABLE TRUST; SANTA FE BUSINESS BROKERS, LLC, d/b/a SAM GOLDENBERG & ASSOCIATES; SUNBELT NEW MEXICO BUSINESS BROKERAGE, LLC; and MICHAEL GREENE,

Defendants,

DWIGHT L. PATTERSON and LAURIE M. PATTERSON, Individually and as Trustees of the PATTERSON REVOCABLE TRUST,

Third-Party Plaintiffs,

v.

XITECH INSTRUMENTS, INC., Third-Party Defendant.

ORDER AFFIRMING MAGISTRATE JUDGE’S PROPOSED FINDINGS AND RECOMMENDED DISPOSITION ON PENDING MOTIONS AND OTHER MATTERS, EXCEPT FOR MATTERS RELATED TO PLAINTIFF SHEPARD BASED ON CHAPTER 7 BANKRUPTCY FILING

THIS MATTER comes before the Court upon Proposed Findings and Recommended Disposition in the above-captioned case entered by United States Magistrate Judge Steven C. Yarbrough on March 2, 2020, see Doc. 76. No objections were filed by any of the relevant parties. For reasons given below, the Court adopts those findings and recommendation except for those related to Plaintiff Shepard in light of his recent filing for Chapter 7 bankruptcy protection on March 4, 2020. See Doc. 77. BACKGROUND The proposed findings and recommendations (“PFRD”) addressed several pending

motions referred to Magistrate Judge Yarbrough pursuant to 28 U.S.C. §636(b)(1)(B) and (b)(3), see Doc. 63. DISCUSSION Under Rule 72(a) of the Federal Rules of Civil Procedure, the Court shall consider objections made by the parties and “shall modify or set aside any portion of the magistrate's order found to be clearly erroneous or contrary to law.” Fed.R.Civ.P. 72(a); see also 28 U.S.C. §636(b)(1)(A) (district judge may “reconsider any pretrial matter . . . where it has been shown that the magistrate’s order is clearly erroneous or contrary to law”); Ehrenhaus v. Reynolds, 965 F.2d 916, 921 (10th Cir. 1992) (court must accept the magistrate’s factual findings unless clearly

erroneous). Judge Yarbrough recommends the imposition of sanctions that would be dispositive of certain claims and issues. In such a situation, Federal Rule of Civil Procedure 72 provides and the Constitution requires, that the district court judge undertake de novo review of that determination upon objection. 28 U.S.C. § 636(b)(1)(A); Fed.R.Civ.P. 72(a). See Gomez v. Martin Marietta Corp., 50 F.3d 1511, 1519 (10th Cir.1995). 1519 (finding that the penalty imposed controls the scope of the magistrate judge's authority); Ocelot Oil Corp. v. Sparrow Indus., 847 F.2d 1458, 1462 (10th Cir.1988). (finding that a magistrate judge's decision on a motion for sanctions dictates which standard of review should apply). The sanctions recommended in the PFRD were considered under Ehrenhaus v. Reynolds, which requires a consideration of the following factors: (1) the degree of actual prejudice to the defendant; (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. 965 F.2d 916, 921 (10th

Cir. 1992). These factors are not rigid, but rather a criteria for consideration. Id. Where a court imposes the harsher sanctions, such as default judgment, due process “requires that failure [to comply with a court order] is a sufficient ground only when it is the result of willfulness, bad faith, or some fault of [the offending party] rather than inability to comply.” M.E.N. Co. v.Control Fluidics, Inc., 834 F.2d 869, 872 (10th Cir. 1987) (internal quotation marks omitted). A “willful failure” is “any intentional failure as distinguished from involuntary noncompliance. No wrongful intent need be shown.” Id. at 872-73 (internal quotation marks omitted). I. Pending Motions and Recommended Dispositions

Judge Yarbrough made the following findings and recommendation: A. Doc. 29: Motion to Dismiss filed by Defendants Santa Fe Business Brokers, LLC, d/b/a Sam Goldenberg & Associates, Sunbelt New Mexico Business Brokerage, LLC, and Michael Greene (“SGA Defendants”) on September 26, 2019, seeking dismissal of Plaintiff Tratt Industry, LLC (“Tratt”) based on its failure to obtain legal representation under D.N.M.LR-Civ. 83.8(c). No response was filed to this motion. Findings and Recommended Disposition: Judge Yarbrough recommended he claims in the Complaint brought by Tratt Industries, LLC, be dismissed with prejudice. He acknowledged that while default judgment is a harsh sanction, Tratt’s failure to obtain counsel was “deliberate and willful” and that default judgment was appropriate under a detailed Ehrenhaus analysis.1 The Court adopts these findings and recommendations. Tratt was advised eight months ago of the need to obtain legal representation as a corporate entity in order to proceed in this case. See Docs. 22 at 2; 35 at 3. The company was afforded several extensions of time in which to do

so, has been warned several times that dismissal of its claims would be a sanction for failing to obtain counsel, and there are no lesser sanctions that are effective for an entity that chooses not to participate in a case. Docs. 35 at 6-7; 54. Tratt’s claims in this lawsuit are therefore dismissed with prejudice. B. Doc. 31 Defendants Dwight L. Patterson and Laurie M. Patterson’s (“Patterson Defendants” or “the Pattersons”) Motion for Default Judgment on Counterclaim against Defendants Tratt, Baker and Shepard, filed October 2, 2019 (no response filed). Findings and Recommended Disposition: Judge Yarbrough noted that a Clerk’s Entry of

Default was already granted as to Tratt by the undersigned as presiding judge. See Docs. 37 at 7 (granting request for entry of default) and 36 (Clerk’s Entry of Default) and thus the Pattersons ’ request for default against Tratt was moot. Judge Yarbrough also recommended that the motion be denied without prejudice as to Plaintiffs Baker and Shepard because they had answered the counterclaims, although they were untimely.

1 Before choosing the sanction of dismissal, the district court should consider the following factors: (1) the degree of actual prejudice to the defendant; (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 v. Reynolds, 965 F.2d 916, 921 (10th Cir. 1992).

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Related

Chambers v. Nasco, Inc.
501 U.S. 32 (Supreme Court, 1991)
Reed v. Bennett
312 F.3d 1190 (Tenth Circuit, 2002)
Ocelot Oil Corporation v. Sparrow Industries
847 F.2d 1458 (Tenth Circuit, 1988)
Gomez v. Martin Marietta Corp.
50 F.3d 1511 (Tenth Circuit, 1995)
M.E.N. Co. v. Control Fluidics, Inc.
834 F.2d 869 (Tenth Circuit, 1987)
Ehrenhaus v. Reynolds
965 F.2d 916 (Tenth Circuit, 1992)

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