United States v. Polynice

District Court, S.D. Florida·Decided June 29, 2022·No. 1:21-cv-24243·Unknown

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

Case No. 21-cv-24243-BLOOM/Otazo-Reyes

UNITED STATES OF AMERICA,

Plaintiff,

v.

FABRICE POLYNICE, HAROLD SIDO, and VERONISE SIDO,

Defendants. ________________________________/

ORDER DENYING MOTION TO SET ASIDE AND VACATE DEFAULT AND DEFAULT FINAL JUDGMENT

THIS CAUSE is before the Court upon Defendants Harold Sido (“Mr. Sido”) and Veronise Sido’s (“Mrs. Sido”) (collectively, “Defendants”) Motion to Set Aside and Vacate Default and Default Final Judgment, ECF No. [30] (“Motion”). Plaintiff United States of America (“Plaintiff” or “Government”) filed a Response in Opposition, ECF No. [31] (“Response”). To date, Defendants have not filed a Reply. The Court has carefully considered the Motion, the record in this case, the applicable law, and is otherwise duly advised. For the reasons that follow, the Motion is denied. I. BACKGROUND On December 2, 2021, the Government filed its Complaint against Defendants, seeking to enforce a Forfeiture Order against Defendants for their violation of the Communications Act of 1934, 47 U.S.C. §§ 151-63 (“Communications Act”). See ECF No. [1]. Defendants were served with the Complaint on January 11, 2022. See ECF Nos. [9], [10]. Defendants failed to respond to the Complaint by the applicable February 1, 2022 deadline. As such, the Court directed Defendants to respond to the Complaint on or before February 9, 2022. See ECF No. [11]. When Defendants failed to respond by the extended deadline, the Government moved for a Clerk’s Entry of Default, see ECF No. [13], and a Clerk’s Default was entered against both Defendants on February 11, 2022, see ECF No. [14]. On February 14, 2022, Mr. Sido filed an untimely Answer. See ECF No. [16] (“Answer”).

The Government filed a Motion to Strike the Answer of Harold Sido, ECF No. [23] (“Motion to Strike”), because the Answer was procedurally improper and failed to properly admit or deny the factual allegations contained in the Complaint. The Court granted the Motion to Strike, striking Mr. Sido’s Answer. See ECF No. [24]. On March 21, 2022, the Government filed a Motion for Default Final Judgment, see ECF No. [25], which the Court also granted, see ECF No. [26]. Default Final Judgment was entered against Defendants on March 23, 2022. See ECF No. [27]. In the instant Motion, Defendants seek to vacate the Default Final Judgment pursuant to Fed. R. Civ. P. 55(c) and 60(b). See ECF No. [30]. Defendants submit that they have a meritorious defense, granting their Motion will not prejudice the Government, and they had good reason for

failing to respond to the Complaint. See id. at 7. Moreover, Defendants submit that the length of any delay was short and that they acted in good faith. See id. The Government responds that Defendants have not established good cause for their failure to respond and they have not established a meritorious defense. See ECF No. [31]. II. LEGAL STANDARD Fed. R. Civ. P. 55(c) states that “[t]he court may set aside an entry of default for good cause, and it may set aside a final default judgment under Rule 60(b).” In turn, Fed. R. Civ. P. 60(b)(1) states that “the court may relieve a party or its legal representative from a final judgment, order, or proceeding for . . . mistake, inadvertence, surprise, or excusable neglect[.]” To establish mistake, inadvertence, or excusable neglect under Rule 60(b)(1), a defaulting party must show that: “(1) it had a meritorious defense that might have affected the outcome; (2) granting the motion would not result in prejudice to the non-defaulting party; and (3) a good reason existed for failing to reply to the complaint.” Florida Physician’s Ins. Co. v. Ehlers, 8 F.3d 780, 783 (11th Cir. 1993). III. DISCUSSION

a. Lack of a Meritorious Defense First, Defendants argue that they have a meritorious defense because they did not intentionally provide support for an illegal radio station. See ECF No. [30] at 2. They also assert that they only learned that the radio station operator – Fabrice Polynice (“Mr. Polynice”) – was using their property to conduct illegal acts when the Government raided and seized Mr. Polynice’s equipment on July 5, 2012. See id. Since then, Defendants contend that they have not allowed Mr. Polynice to use their property for any reason. See id. With regard to the Forfeiture Order, Defendants argue that their joint liability for a fine of $144,344.00, plus costs, is excessive and violates their rights under the Eighth Amendment of the United States Constitution. See id.

The Government responds that Defendants fail to set forth a meritorious defense. See ECF No. [31] at 6-10. According to the Government, intentional conduct is not required for liability under the Communications Act. See id. at 6-7. A penalty may be imposed for any “willful” failure to comply with the Communications Act. See id. “[T]he term ‘willful,’ when used with reference to the commission or omission of any act, means the conscious and deliberate commission or omission of such act, irrespective of any intent to violate any provision of this chapter or any rule or regulation of the Commission authorized by this chapter . . . .” 47 U.S.C. § 312(f)(1) (emphasis added). In this case, the Complaint alleges, and the record evidence establishes, that there were several notices informing Defendants of the unauthorized operation of an illegal radio station on their property, which were signed by Defendants. See id. at 7-8. Thus, according to the Government, the Government need only establish that Defendants permitted the illegal radio broadcast on their property, and the record evidence amply establishes as much. With regard to the Forfeiture Order, the Government argues that the forfeiture assessed against Defendants falls within the statutory range. See 47 U.S.C. § 503(b)(2)(D). Section 503(b)(2)(D) authorizes a

forfeiture against Defendants of up to $19,246.00 for each day of a continuing violation, up to a statutory maximum of $144,344.00, for a single act or failure to act, adjusted for inflation. See ECF No. [31] at 8. The Court agrees with the Government. The bar for stating a meritorious defense for Rule 60(b)(1) purposes is low: “the ‘likelihood of success is not the measure’ . . . [i]nstead, it is sufficient where a Defendant has provided by clear statements a ‘hint of a suggestion’ that his case has merit.” Rodriguez v. Brim’s Food, Inc., No. 13-CV-20600, 2013 WL 3147348, at *3 (S.D. Fla. June 19, 2013) (citations omitted); see also Argoitia v. C & J Sons, LLC, No. 13-62469-Civ, 2014 WL 1912011, at *2 (S.D. Fla. May 13, 2014) (“[T]he proper measure is whether Defendants have

provided by ‘clear statements’ a ‘hint of a suggestion’ that their defenses have merit.” (citation omitted)). Even applying this low standard, Defendants have failed to set forth a colorable argument for a meritorious defense. First, even if the Court were to assume that Defendants did not intentionally provide support for an illegal radio station, as the Government correctly argues, intent to violate the Communications Act is not required for liability under the Communications Act. See 47 U.S.C.

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