Liberty Mutual Insurance Company v. Vila Construction Company, et al.
- Phyllis Hamilton
- 4:19-cv-07306
- U.S. District Court · Northern District of California
- 4
In Liberty Mutual v. Vila Construction, Judge Hamilton denied Richard H. Vila’s motion to vacate an amended abstract of judgment and vacated the hearing date.
Richard H. Vila’s motion was denied, and the amended abstract of judgment was not vacated. Vila Construction Company was also expressly treated as excluded from the settlement or satisfaction described in the opinion. The court vacated the November 6 hearing date.
What happened
In Liberty Mutual Insurance Company v. Vila Construction Company, et al., Richard H. Vila asked the court to cancel an amended abstract of judgment that Liberty Mutual filed in August 2025. He argued that Liberty Mutual had already acknowledged full satisfaction of the judgment in 2022.
Liberty Mutual argued that the 2022 settlement and satisfaction applied only to certain defendants and expressly excluded Richard H. Vila individually and Vila Construction Company. It also argued that the rules governing judgments did not control an abstract of judgment. The court relied on the settlement’s wording and on California procedure governing satisfaction of judgments.
Judge Phyllis J. Hamilton denied Vila’s motion to vacate the amended abstract of judgment and vacated the November 6 hearing date.
The detailed version
- Liberty Mutual Insurance Company v. Vila Construction Company, et al. · No. 4:19-cv-07306
- Phyllis Hamilton
- Nov. 4, 2025
Background
Liberty Mutual Insurance Company filed an amended abstract of judgment on August 7, 2025, and the court entered it on August 12, 2025. Defendant Richard H. Vila moved to vacate it under Federal Rules of Civil Procedure 59 and 60. The motion concerned whether a prior acknowledgment of satisfaction of judgment filed in October 2022 eliminated additional obligations involving Vila and Vila Construction Company.
Arguments
Vila argued that Liberty Mutual’s October 2022 filing checked a box stating that the judgment was satisfied in full. He contended that Rules 59 and 60 required any amendment to a judgment to be made within 28 days under Rule 59 or within one year under Rule 60.
Liberty Mutual argued that the settlement agreement expressly excluded Richard H. Vila individually and Vila Construction Company from the full satisfaction of judgment. The agreement stated that they reaffirmed their obligations, that Liberty Mutual would file a full satisfaction as to Vila individually only if specified obligations were satisfied, and that the agreement did not release or waive Liberty Mutual’s rights against them. Liberty Mutual also pointed out that the October 2022 satisfaction filing applied only to some defendants and identified Vila only as trustee of the RMV Family Trust; it did not include Vila Construction Company.
Liberty Mutual further argued that Rules 59 and 60 did not apply because the dispute involved an abstract of judgment rather than a judgment. It relied on Rule 69(a), which governs proceedings used to enforce money judgments and requires use of the procedure of the state where the court is located. Liberty Mutual cited a California appellate decision holding that the parties’ intent expressed in a release controls whether a satisfaction applies to particular defendants.
Court’s ruling
The court agreed that the California decision applied. It found that both the settlement agreement and the satisfaction of judgment clearly and specifically excluded Vila and Vila Construction Company from the settlement or satisfaction. The court rejected Vila’s arguments and stated that he was attempting to rely on a satisfaction of judgment that did not apply to him.
The court DENIED Richard H. Vila’s motion to vacate the amended abstract of judgment. It also vacated the November 6 hearing date.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.