Jones v. National Railroad Passenger Corporation

Background

Amanda Jones brought a diversity action against the Santa Cruz Metropolitan Transit District (SCMTD). After a jury trial, the jury returned a unanimous verdict for Jones in the amount of $12,999,250. Jones accepted the court’s reduction of economic damages to $27,000, and the court denied SCMTD’s motion for a new trial. On June 20, 2025, the court entered an amended judgment for Jones against SCMTD in the amount of $12,658,250, with post-judgment interest calculated from March 19, 2025, at 4.04 percent. SCMTD appealed to the Ninth Circuit.

SCMTD then moved under Federal Rule of Civil Procedure 62 to stay enforcement of the judgment while its appeal proceeded and to waive the usual requirement of posting a supersedeas bond. A supersedeas bond is security intended to protect the judgment creditor while enforcement is paused during an appeal. Jones asked the court to deny the motion or require SCMTD to post a full bond.

California-law argument

The court held that California law did not require a bond waiver in this federal proceeding. California law exempts certain public entities from bond requirements, including a district or public agency. SCMTD argued that this state-law protection applied in federal court.

The court rejected that argument under Ninth Circuit precedent. It concluded that Rule 62 is a federal procedural rule governing a judgment debtor’s monetary obligations during an appeal. Because Rule 62 applies, the court held that California Code of Civil Procedure section 995.220 does not replace or override Rule 62’s bond procedures.

Rule 62(f)

The court also rejected SCMTD’s argument under Rule 62(f). That rule gives a judgment debtor the same stay available under state law when the judgment is a lien on the debtor’s property under the law of the state where the court is located. The court found that SCMTD had not established that the amended judgment was currently a lien on its property under California law. The possibility that the judgment might become a lien in the future was not enough.

Rule 62(b) and the Dillon factors

The court nevertheless exercised its discretion under Rule 62(b) to waive the bond requirement. Courts in the Ninth Circuit use five factors, known as the Dillon factors, to decide whether waiver is appropriate:

The court found that the first four factors favored waiver. It accepted SCMTD’s evidence that it had an established process for paying judgments, that judgments were typically paid within a few days, and that substantial coverage was available to pay the amended judgment. The court also found that the estimated $3 million to $5 million bond cost would be a wasteful use of taxpayer money if SCMTD could already pay the judgment.

The fifth factor did not favor waiver because SCMTD had not shown that posting a bond would disadvantage its current creditors. On balance, however, the court found that the other factors supported waiving the bond.

Disposition

The court held that SCMTD was not entitled to a bond waiver under California law or Rule 62(f), but it granted SCMTD’s motion under Rule 62(b). The court therefore GRANTED SCMTD’s Motion for Stay of Execution of Judgment and To Waive Requirement of Bond, pending SCMTD’s appeal to the Ninth Circuit.