Sandeep Roy Chauhan v. Google Inc.

Background

Sandeep Roy Chauhan, proceeding without a lawyer, sued Google over access to Gmail accounts and related stored files. He said one account belonged to his father, who died in February 2021, and that he sought access as the alleged administrator or heir of his father’s estate. Google did not respond after being served, and the clerk entered Google’s default.

Chauhan filed a motion seeking production of the deceased person’s Google account contents. He later moved for default judgment. Unlike his complaints, the default-judgment motion referred to three Gmail accounts, sought $18,000 in compensatory damages and $1,200 in attorney’s fees, and requested either reinstatement of the accounts or permission to download their data.

Court’s analysis

The court explained that entry of default does not automatically entitle a plaintiff to a judgment. Before considering default judgment, a court must examine its jurisdiction. Chauhan’s complaints cited the Stored Communications Act and the Electronic Communications Privacy Act, but the court found that he did not clearly assert a claim under either statute. Even assuming the complaints could be read to assert such claims, the court found that the submitted documents did not adequately establish that Chauhan was legally authorized to obtain the account data or that his father was the sole account holder of the account identified in the complaints.

The court also found that diversity of citizenship existed because the opinion stated that Google was headquartered in the district and Chauhan resided in India. But the record did not show that the amount in controversy exceeded $75,000, the required threshold for diversity jurisdiction.

Finally, Federal Rule of Civil Procedure 54(c) provides that a default judgment cannot differ in kind from, or exceed in amount, the relief demanded in the pleadings. The court found that Chauhan’s default-judgment request substantially differed from and exceeded the relief requested in his complaints, which sought access to one account but did not request damages or attorney’s fees.

Disposition

Because not all parties had consented to the magistrate judge’s jurisdiction, the court ordered this case and the related case to be reassigned to a district judge. The court recommended that Chauhan’s motion to produce the account contents be denied and that his motion for default judgment be denied. The court did not address the remaining default-judgment factors after determining that jurisdiction was lacking and that the requested judgment did not satisfy Rule 54(c).