United States v. Berry

CourtDistrict Court, E.D. Wisconsin
DecidedNovember 27, 2024
Docket2:24-cv-00569
StatusUnknown

This text of United States v. Berry (United States v. Berry) is published on Counsel Stack Legal Research, covering District Court, E.D. Wisconsin primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Berry, (E.D. Wis. 2024).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN

UNITED STATES OF AMERICA,

Plaintiff, Case No. 24-cv-569-pp v.

NAHDIKA BERRY,

Defendant.

ORDER GRANTING MOTION FOR DEFAULT JUDGMENT (DKT. NO. 4) AND DISMISSING CASE

On May 8, 2024, the plaintiff filed a complaint alleging that the defendant had defaulted on her federal student loans. Dkt. No. 1. At some point between May 8 and July 24, 2024, the defendant executed a waiver of service; the plaintiff filed that waiver with the court on July 24, 2024. Dkt. No. 3. In the four months since the plaintiff filed the waiver of service, the court has received nothing from the defendant. On September 19, 2024, the plaintiff filed a combined request for entry of default and judgment and a supporting declaration. Dkt. Nos. 4, 5. The clerk entered default on the same day. Although the plaintiff’s filing is procedurally improper, the court will grant the plaintiff’s request and enter default judgment against the defendant. I. Entry of Default Federal Rule of Civil Procedure 55 requires a two-step process before the entry of default judgment. A party first must seek an entry of default based on the opposing party’s failure to plead. Fed. R. Civ. P. 55(a). This means that the court must assure itself that the defendant was aware of the suit and still did not respond. The plaintiff’s counsel filed a declaration in support of the request for

default and motion for default judgment. Dkt. No. 5. The declaration did not explain when the plaintiff sent the defendant the Notice of a Lawsuit and Request to Waive Service of a Summons or how. However, the plaintiff attached to the complaint a copy of the Notice of a Lawsuit and Request to Waive Service of a Summons, which certified that the plaintiff’s counsel had sent it to the defendant on May 8, 2024. Dkt. No. 3 at 3. The notice advised the defendant that to avoid expenses, the defendant must return the signed waiver within thirty (30) days from the date at the bottom of the Notice (May 8, 2024). Id.

That comports with Fed. R. Civ. P. 4(d)(1)(F), which requires a plaintiff to “give the defendant a reasonable time of at least 30 days after the request was sent . . . to return the waiver.” The notice advised the defendant that if she executed the waiver, the plaintiff would file the executed waiver on the docket and the defendant would have sixty (60) days to answer the complaint. Id. Thirty days from May 8, 2024 was June 7, 2024. The affidavit from the plaintiff’s counsel avers that “[o]n July 24, 2024, the defendant’s waiver of

service was returned and filed on the docket.” Dkt. No. 5 at ¶3. It appears, then, that the defendant returned the executed waiver of service form well over thirty days after the date on the notice, and thus that the waiver was not timely filed. Nonetheless, the plaintiff filed the Waiver of the Service of Summons with the court. Dkt. No. 3 at 1. The Notice of a Lawsuit and Request to Waive Service of a Summons advised the defendant that if she returned the signed waiver, the plaintiff’s

counsel would file it with the court and the case “will then proceed as if you had been served on the date the waiver is filed . . . .” Id. at 3. That comports with Fed. R. Civ. P. 4(d)(4), which states that when a plaintiff files an executed waiver with the court, the summons and complaint are considered to have been served at the time of the filing of the waiver. The waiver was not filed by the plaintiff’s counsel until July 24, 2024. Dkt. No. 3. That means that the defendant was “served” on July 24, 2024. The Notice of a Lawsuit and Request to Waive Service of a Summons also

advised the defendant that she would have sixty (60) days from the date the notice was sent—May 8, 2024—by which to answer the complaint. Id. at 3. Fed. R. Civ. P. 12(a)(1)(A)(ii) says that if a defendant has timely waived service under Fed. R. Civ. P. 4(d), a defendant must answer “within 60 days after the request for a waiver was sent . . . .” The court has noted that the defendant did not timely waive service, but the plaintiff appears to have elected to ignore that fact.

The Waiver of the Service of Summons appears to have been signed by the defendant. In signing the form, the defendant acknowledged that if she did not file and serve an answer or a motion under Rule 12 with 60 days from May 8, 2024, “a default judgment [would] be entered against [her] . . . .” Id. Sixty days from the date the notice was sent was July 7, 2024. But only defendants who “timely” return a waiver receive an extended sixty days to respond to the complaint; the defendant did not return the waiver form within the time requested by the plaintiff, so she could not take advantage of the extended time

to answer. Fed. R. Civ. P. 4(d)(3), 12(a)(1)(A)(ii). That means the defendant had twenty-one days from the July 24, 2024 date of service—that is, until August 14, 2024—to respond to the complaint. Fed. R. Civ. P. 12(a)(1)(A)(i). As of the date of this order, the defendant has not answered or otherwise responded to the complaint. The court is satisfied that the plaintiff notified the defendant of the lawsuit and that the defendant waived service. The clerk properly entered default against the defendant on September 19, 2024, well over twenty-one

days after the plaintiff filed the executed waiver of service. II. Plaintiff’s Request for Entry of Default and Judgment Once the clerk has entered default, Rule 55(b) states that a party “must apply to the court for a default judgment.” When the court determines that a defendant is in default, the court accepts as true the well-pleaded allegations in the complaint. e360 Insight v. The Spamhaus Project, 500 F.3d 594, 602 (7th Cir. 2007). “A default judgment establishes, as a matter of law, that defendants

are liable to plaintiff on each cause of action in the complaint.” Id. However, “even when a default judgment is warranted based on a party’s failure to defend, the allegations in the complaint with respect to the amount of damages are not deemed true.” Id. (quoting In re Catt, 38 F.3d 789, 793 (7th Cir. 2004)). A district court “must conduct an inquiry in order to ascertain the amount of damages with reasonable certainty.” Id. Rule 55(b)(2) allows the district court to conduct this inquiry through hearings or referrals, if necessary, to determine the amount of damages. Fed. R. Civ. P. 55(b). Such proceedings are

unnecessary, however, if the “amount claimed is liquidated or capable of ascertainment from definite figures contained in the documentary evidence or in detailed affidavits.” e360 Insight, 500 F.3d at 602 (quoting Dundee Cement Co. v Howard Pipe & Concrete Prods., Inc., 722 F2d 1319, 1323 (7th Cir. 1983)). The plaintiff did not file a separate motion for default judgment. Instead, the plaintiff filed a combined “Request for Entry of Default and Judgment.” Dkt. No. 4.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

United States v. Lawrence
276 F.3d 193 (Fifth Circuit, 2001)
E360 INSIGHT v. the Spamhaus Project
500 F.3d 594 (Seventh Circuit, 2007)
United States v. Petroff-Kline
557 F.3d 285 (Sixth Circuit, 2009)

Cite This Page — Counsel Stack

Bluebook (online)
United States v. Berry, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-berry-wied-2024.