Valtierra v. Warden Security Associates, Inc.
- Beth Freeman
- 5:24-cv-00496
- U.S. District Court · Northern District of California
- 4
In Valtierra v. Warden Security Associates, Judge Van Keulen ordered more information before deciding Valtierra’s default-judgment motion.
Jisela Valtierra and Warden Security Associates, Inc.; the order requires Valtierra to provide more information before the court decides her request for default judgment.
What happened
In Valtierra v. Warden Security Associates, Inc., Jisela Valtierra sought a judgment because the company did not respond to her Title VII claims alleging sex and pregnancy discrimination, denial of pregnancy accommodation, and retaliation.
The court found that the company was properly served, that the court had authority to hear the case, and that Valtierra’s allegations were sufficient to establish potential liability. But the motion did not provide enough information about the amount of money sought, including whether it covered lost wages, non-wage damages, or both.
The court did not yet decide the default-judgment motion. Judge Susan Van Keulen ordered Valtierra to provide additional information and calculations by November 7, 2024, and to serve the order and supplemental submission on the company through its registered agent and business address.
The detailed version
- Valtierra v. Warden Security Associates, Inc. · No. 5:24-cv-00496
- Beth Freeman
- Oct. 8, 2024
Background
Jisela Valtierra sued Warden Security Associates, Inc. under Title VII, alleging sex and pregnancy discrimination, denial of pregnancy accommodation, and retaliation. The complaint was served through the company’s registered agent. The company did not respond, so the clerk entered default. Valtierra then filed a motion for default judgment.
Court’s analysis
Before entering default judgment, the court examined whether service was proper and whether it had subject-matter jurisdiction, meaning legal authority over the type of case, and personal jurisdiction over the defendant. The court found that service through the company’s registered agent complied with the applicable rules and that the Title VII claims provided subject-matter jurisdiction.
The court then considered the factors used to decide whether to enter default judgment. It found that the complaint and motion, including Valtierra’s declaration, adequately supported potential liability. The court also found that refusing default judgment would prejudice Valtierra because she had no other recourse against the company, and it found no indication that the company’s failure to respond resulted from excusable neglect or that material facts were disputed. Although federal procedure generally favors decisions on the merits, the court noted that the company’s refusal to participate made litigation on the merits unlikely.
The court could not evaluate the factor concerning the amount of money at stake because the motion did not clearly identify the damages sought. In particular, the proposed judgment did not make clear whether the requested amount covered lost wages, non-wage damages, or both. The opinion also reproduced a proposed amount described as “forty-eight thousand six hundred seventy-two dollars ($48.67).”
Order
The court ordered Valtierra to submit additional information supporting her motion by November 7, 2024. The supplemental submission must include affidavits supporting non-wage damages, clarify and calculate the total judgment sought, and separately identify lost-wage damages, non-wage damages, and non-monetary relief. Valtierra was also ordered to serve the order and the supplemental submission by mail on the company’s registered agent and business address and to file proof of service. The court did not yet grant or deny the motion for default judgment.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.