Upstate Mobile Tire, LLC v. Tread Connection International, LLC

CourtDistrict Court, W.D. North Carolina
DecidedAugust 1, 2024
Docket3:23-cv-00076
StatusUnknown

This text of Upstate Mobile Tire, LLC v. Tread Connection International, LLC (Upstate Mobile Tire, LLC v. Tread Connection International, LLC) is published on Counsel Stack Legal Research, covering District Court, W.D. North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Upstate Mobile Tire, LLC v. Tread Connection International, LLC, (W.D.N.C. 2024).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION 3:23-cv-00076-RJC-SCR ________________________________________ UPSTATE MOBILE TIRE, LLC,

Petitioner, ORDER

v.

TREAD CONNECTION

INTERNATIONAL, LLC, et al.,

Respondents.

THIS MATTER is before the Court on Petitioner Upstate Mobile Tire, LLC’s Motion for Default Judgment. (Doc. No. 9). For the reasons explained below, Petitioner’s motion is GRANTED. I. BACKGROUND On February 9, 2023, Petitioner Upstate Mobile Tire, LLC filed an Application to Confirm Arbitration Award against Respondent Tread Connection International, LLC. (Doc. No. 1). On June 29, 2023, Petitioner filed an amended Application to Confirm Arbitration Award against Respondent Tread Connection, LLC (“Respondent”). (Doc. No. 3). On August 30, 2023, Petitioner filed a Motion to Serve Process Upon the North Carolina Secretary of State. (Doc. No. 5). In its motion, Petitioner indicated that Respondent had been administratively dissolved by the North Carolina Secretary of State and that Petitioner tried unsuccessfully to serve an officer associated with Respondent. (Id. at ¶¶ 2–3). Magistrate Judge Rodriguez granted Petitioner’s motion. On September 8, 2023, Petitioner filed a Certificate of Service, (Doc. No. 6),

and letter from the Secretary of State, (Doc. No. 6-1), indicating that the Secretary of State accepted service on September 5, 2023. On September 12, 2023, the Court set a deadline requiring Respondent to file its answer by September 27, 2023. Respondent failed to respond in a timely manner. On October 10, 2023, Petitioner moved for entry of default, (Doc. No. 7), and the Clerk of Court entered default against Respondent on October 13, 2023. (Doc. No. 8). On December 21, 2023, Petitioner moved for default judgment. (Doc. No. 9).

II. STANDARD OF REVIEW a. Default Judgment Standard Under Rule 55 of the Federal Rules of Civil Procedure, “[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 must enter the party’s default.” Fed. R. Civ. P. 55(a). Upon the entry of default, the defaulted party

is deemed to have admitted all well-pleaded allegations of fact contained in the complaint. Ryan v. Homecomings Fin. Network, 253 F.3d 778, 780 (4th Cir. 2001); J & J Sports Prods., Inc. v. Romenski, 845 F. Supp. 2d 703, 705 (W.D.N.C. 2012); see also Fed. R. Civ. P. 8(b)(6) (“An allegation—other than one relating to the amount of damages—is admitted if a responsive pleading is required and the allegation is not denied.”). The defendant is not deemed, however, to have admitted conclusions of law, and the entry of “default is not treated as an absolute confession by the defendant of his liability and of the plaintiff’s right to recover.” Ryan, 253 F.3d at 780 (citations omitted); see also J & J Sports Prods., 845 F. Supp. 2d at 705; EEOC v. Carter

Behavior Health Servs., 2011 U.S. Dist. LEXIS 129493, 2011 WL 5325485, at *3 (E.D.N.C. Oct. 7, 2011). Rather, in determining whether to enter judgment on the default, the court must determine whether the well-pleaded allegations in the complaint support the relief sought. See Ryan, 253 F.3d at 780; DIRECTV, Inc. v. Pernites, 200 F. App’x 257, 258 (4th Cir. 2006) (a “defendant is not held to admit facts that are not well-pleaded or to admit conclusions of law”); J & J Sports Prods., 845 F. Supp. 2d at 705; 10 A Wright, Miller & Kane, Federal Practice and Procedure

§ 2688 (3d ed. Supp. 2010) (“[L]iability is not deemed established simply because of the default . . . and the court, in its discretion, may require some proof of the facts that must be established in order to determine liability.”). To that end, the Fourth Circuit has “repeatedly expressed a strong preference that, as a general matter, defaults be avoided and that claims and defenses be disposed of on their merits.” Colleton Preparatory Acad., Inc. v. Hoover Univ., Inc.,

616 F.3d 413, 417 (4th Cir. 2010) (citations omitted). Nonetheless, default judgment “may be appropriate when the adversary process has been halted because of an essentially unresponsive party.” SEC v. Lawbaugh, 359 F. Supp. 2d 418, 421 (D. Md. 2005). If the court finds that liability is established, it must then determine damages. J & J Sports Prods., 845 F. Supp. 2d at 706 (citing Ryan, 253 F.3d at 780–81). The court must make an independent determination regarding damages and cannot accept as true factual allegations of damages. Id. (citing Lawbaugh, 359 F. Supp. 2d at 422); Anheuser Busch, Inc. v. Philpot, 317 F.3d 1264, 1266 (11th Cir. 2003) (noting the court must “assure that there is a legitimate basis for any damage award it

enters.”). While the court may conduct an evidentiary hearing to determine damages, it is not required to do so, but may rely instead on affidavits or documentary evidence in the record to determine the appropriate sum. See EEOC v. CDG Mgmt., LLC, No. RDB-08-2562, 2010 U.S. Dist. LEXIS 124919, 2010 WL 4904440, at *2 (D. Md. Nov. 24, 2010) (citations omitted); EEOC v. North Am. Land Corp., No. 1:08-cv-501, 2010 U.S. Dist. LEXIS 78928, 2010 WL 2723727, at *2 (W.D.N.C. July 8, 2010). b. Confirmation of Arbitration Award Standard

Section 9 of the Federal Arbitration Act provides: If the parties in their agreement have agreed that a judgment of the court shall be entered upon the award made pursuant to the arbitration, and shall specify the court, then at any time within one year after the award is made any party to the arbitration may apply to the court so specified for an order confirming the award, and thereupon the court must grant such an order unless the award is vacated, modified, or corrected as prescribed in sections 10 and 11 of this title. If no court is specified in the agreement of the parties, then such application may be made to the United States court in and for the district within which such award was made. Notice of the application shall be served upon the adverse party, and thereupon the court shall have jurisdiction of such party as though he had appeared generally in the proceeding.

See also Cortez Byrd Chips, Inc. v. Bill Harbert Constr. Co., 529 U.S. 193, 195–204 (2000) (holding that the FAA’s venue provisions are permissive and that a motion to confirm an arbitration award may also be made in any district proper under the general venue statute). “[J]udicial review of arbitration awards is extremely limited – in fact, it is ‘among the narrowest known to the law.’” U.S. Postal Serv. v. Am. Postal Workers Union, 204 F.3d 523, 527 (4th Cir. 2000) (quoting Union P.R. Co. v. Sheehan, 439 U.S.

89, 91, 99 S. Ct. 399, 58 L. Ed. 2d 354 (1978)).

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Anheuser-Busch v. Irvin P. Philpot, III
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Directv, Inc. v. Pernites
200 F. App'x 257 (Fourth Circuit, 2006)
Securities & Exchange Commission v. Lawbaugh
359 F. Supp. 2d 418 (D. Maryland, 2005)
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845 F. Supp. 2d 703 (W.D. North Carolina, 2012)

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Upstate Mobile Tire, LLC v. Tread Connection International, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/upstate-mobile-tire-llc-v-tread-connection-international-llc-ncwd-2024.