Peralta v. PCS USA LLC

Background

Yafreici Peralta originally brought federal and state claims for discrimination, harassment, and unpaid wages against PCS USA LLC and Louis Van Leeuwen. She later added breach-of-contract and retaliation claims.

After a settlement conference, the parties entered into a written settlement agreement. The agreement required the defendants to pay Peralta $55,090.07: a $2,090.07 one-time payment, a $5,000 payment, and $48,000 in equal installments over 24 months. In return, Peralta released her claims through August 15, 2024. The court's dismissal order retained jurisdiction, meaning the court kept authority to enforce the agreement.

The defendants made the two one-time payments and the first two installment payments, totaling $11,090.07. They made no payments after August 31, 2024. The court reopened the case for the limited purpose of addressing Peralta's enforcement motion. The defendants did not file an opposition and later informed the court that they had no funds available to pay Peralta.

Court's Analysis

The court held that the enforcement motion was properly before it because the dismissal order expressly retained jurisdiction over disputes and breaches of the settlement agreement.

Applying New York contract law, the court explained that a breach-of-contract claim requires proof that the plaintiff performed under the contract, the defendant breached it, and the plaintiff suffered damages. The court found that Peralta performed her part of the agreement by releasing her claims. It also found that the defendants breached the agreement by failing to make the required payments, causing damages equal to the unpaid amounts.

The court determined that $44,000 remained due on the principal balance. It also awarded $140.82 in interest on six overdue $2,000 installments due from September 30, 2024 through February 28, 2025. Although the agreement described the interest as 5% "per diem," the court calculated the interest for each installment by multiplying the payment by 5%, dividing by 365, and multiplying by the number of unpaid days.

The court also awarded post-judgment interest under 28 U.S.C. § 1961. The opinion notes that the March 11, 2025 opinion and order was amended to remove an instruction directing the Clerk of Court to calculate that interest.

Disposition

The court granted Peralta's motion to enforce the settlement agreement. It entered judgment in Peralta's favor and against the defendants for $44,140.82, consisting of $44,000 in principal and $140.82 in interest on past-due installments, plus post-judgment interest under 28 U.S.C. § 1961. The Clerk of Court was directed to close the motion and the case.