A&C Trade Consultants, Inc. v. Alvarez
- Maxine Chesney
- 3:18-cv-05356-MMC
- U.S. District Court · Northern District of California
- 2
In A&C Trade Consultants v. Alvarez, Judge Chesney denied A&C’s request for $632,115.81 in prejudgment interest because its complaint did not request it.
A&C Trade Consultants, Inc.’s request for $632,115.81 in prejudgment interest was denied. This order addressed that request after the court had granted default judgment against Joel E. Alvarez.
What happened
In A&C Trade Consultants, Inc. v. Alvarez, A&C sought prejudgment interest after the court had granted its request for a default judgment against Joel E. Alvarez.
A&C asked for $632,115.81 in prejudgment interest. The court noted that A&C’s complaint listed eight forms of relief but did not request prejudgment interest. Its general request for other appropriate relief did not give sufficient notice that prejudgment interest might be awarded.
Judge Maxine M. Chesney denied A&C’s request under the rule limiting a default judgment to the relief demanded in the pleadings.
The detailed version
- A&C Trade Consultants, Inc. v. Alvarez · No. 3:18-cv-05356-MMC
- Maxine Chesney
- Aug. 24, 2021
Background
A&C Trade Consultants, Inc. brought claims against five defendants, including Joel E. Alvarez. On July 12, 2021, the court granted A&C’s motion for default judgment against Alvarez. A&C later submitted a brief requesting $632,115.81 in prejudgment interest.
Issue
The issue was whether A&C could receive prejudgment interest through the default judgment when its complaint did not specifically request that relief.
Reasoning
Federal Rule of Civil Procedure 54(c) provides that a default judgment must not differ in kind from the relief demanded in the pleadings. The court found that A&C’s complaint listed eight specific forms of relief but did not plead or request prejudgment interest. The complaint’s general request for all other appropriate relief did not count as a demand for prejudgment interest. Because A&C had not requested that relief and had not given meaningful notice that it might be awarded, the court concluded that A&C could not recover prejudgment interest.
Ruling
Judge Maxine M. Chesney ordered that A&C’s request for prejudgment interest was DENIED.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.