Huntington National Bank v. Campisi Environmental Associates, Inc.

Background

Huntington National Bank, identified as the successor-by-merger to TCF National Bank, sought a default judgment against Campisi Environmental Associates, Inc., doing business as Corporate Environmental Advisors, and Joseph S. Campisi. Huntington alleged that Campisi Environmental purchased software and equipment from Bright Vanguard LLC and financed the purchase through agreements with TCF.

The agreements included an Installment Payment Agreement, a Pay Proceeds and Acceptance Confirmation, a Continuing Guaranty signed by Joseph S. Campisi, and an authorization for automatic electronic payments. Under the Installment Payment Agreement, TCF financed $284,470.67, and Campisi Environmental agreed to make 60 monthly payments of $5,550.42. The guaranty stated that Joseph S. Campisi unconditionally and absolutely guaranteed Campisi Environmental’s payment obligations.

Campisi Environmental stopped making monthly payments in June 2021. TCF sent notices of default on July 20, 2021, and September 17, 2021. The defendants did not pay, respond to the lawsuit, or otherwise appear. The clerk entered their default. Although the complaint included six counts, Huntington’s default-judgment motion addressed only Counts I and II, which alleged breach of contract against Campisi Environmental and Joseph S. Campisi.

Court’s analysis

A default judgment may be entered only if the complaint’s factual allegations, other than allegations about damages, establish a valid legal claim. The court concluded that Huntington had adequately alleged breach-of-contract claims under Minnesota law. Those claims required a contract, Huntington’s performance of required conditions, and the defendants’ breach.

The court found that Huntington adequately alleged the formation of the Installment Payment Agreement and guaranty, Huntington’s performance, the defendants’ failure to make required payments, and damages. The agreements contained Minnesota choice-of-law provisions, so the court applied Minnesota law.

Because Huntington sought money, it still had to prove its actual damages with reasonable certainty despite the defendants’ default. The court found that Huntington had done so. The court also found that the Installment Payment Agreement authorized recovery of applicable unpaid amounts, a five-percent penalty, late fees, attorneys’ fees, costs, and expenses. Huntington submitted documentation supporting its request for $7,259.30 in attorneys’ fees and costs, which the court found reasonable and supported.

The court further determined that federal law governed post-judgment interest. It held that interest would accrue from the date judgment was entered on the total award, including attorneys’ fees and costs, at the rate described in 28 U.S.C. § 1961.

Ruling and award

Judge Eric C. Tostrud granted Plaintiff’s Motion for Default Judgment. The order required Huntington to recover from the defendants jointly and severally:

- $49,953.78 for nine unpaid monthly installments from June 2021 through February 2022; - $208,111.50 representing the present value of 42 remaining installments; - $10,405.58 as a five-percent penalty; - $4,995.36 in late fees; - $7,259.30 in attorneys’ fees and costs; and - post-judgment interest at the maximum rate allowed by law, accruing from the date judgment was entered until the judgment was satisfied and calculated as described in 28 U.S.C. § 1961(b).

The court directed that judgment be entered accordingly.