Elevation Health LLC v. Sun Group Partners LLC
- Paul Engelmayer
- 1:22-cv-10155
- U.S. District Court · Southern District of New York
- 2
In Elevation Health v. Sun Group, Judge Figubredo ordered briefing on Delaware damages and prejudgment interest after a default judgment.
Elevation Health LLC must provide additional briefing before the court determines damages on its breach-of-contract claim against Sun Group Partners LLC.
What happened
Elevation Health LLC obtained a default judgment against Sun Group Partners LLC and asked the court to determine damages for its breach-of-contract claim. The court noted that the parties’ promissory note selects Delaware law, while Elevation Health’s filing discussed New York law.
The court directed Elevation Health to explain the proper damages measure under Delaware law, particularly for breaching a promissory note. It also asked whether Delaware law allows prejudgment interest when the contract already provides for interest on unpaid principal and, if so, what interest rate applies.
Judge Figubredo ordered Elevation Health to submit a letter answering those questions by January 31, 2025. The order did not determine the amount of damages or resolve which law governs the damages calculation.
The detailed version
- Elevation Health LLC v. Sun Group Partners LLC · No. 1:22-cv-10155
- Paul Engelmayer
- Jan. 17, 2025
Background
Elevation Health LLC received a default judgment against Sun Group Partners LLC and then sought damages on its breach-of-contract claim. The opinion states that the claim is based on a promissory note. Elevation Health’s memorandum referred to New York law but did not address whether New York or Delaware law governs the damages calculation. The note states that it is governed by and construed under Delaware law.
Issues Identified by the Court
The court asked Elevation Health to address two issues:
1. What is the proper measure of damages for breach of contract under Delaware law, particularly when the breached contract is a promissory note? 2. Does Delaware law permit prejudgment interest on a breach-of-contract damages award when the contract also provides for interest on unpaid principal? If so, what Delaware interest rate applies?
The court also noted that Elevation Health did not request prejudgment interest in its complaint or in its submissions supporting the damages inquest.
Order
The court directed Elevation Health to submit a letter answering these questions by January 31, 2025. The order did not decide the applicable law, the proper damages measure, the availability or rate of prejudgment interest, or the amount of damages. This is a procedural order concerning further briefing in the damages inquest.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.