SeaCube Containers LLC v. PT Lintas Kumala Abadi
- Alvin Hellerstein
- 1:19-cv-10201
- U.S. District Court · Southern District of New York
- 2
In SeaCube Containers v. PT Lintas, Judge Hellerstein required more information before deciding SeaCube’s default-judgment damages request.
SeaCube Containers LLC and PT Lintas Kumala Abadi, particularly SeaCube’s request for damages and attorney fees in its default-judgment motion.
What happened
SeaCube Containers LLC sued PT Lintas Kumala Abadi for allegedly breaching a contract to lease ocean containers. PT Lintas did not appear, and the court issued a certificate of default.
SeaCube asked the court to enter a default judgment under Federal Rule of Civil Procedure 55. The court explained that a default admits well-pleaded allegations supporting liability, but the damages claimed are not automatically accepted as true.
Judge Hellerstein ordered SeaCube to provide additional information within two weeks before the court could calculate damages and enter a default judgment. The requested information included the lease and related documents, attorney time records supporting $14,706 in fees, and an explanation for differences between the damages amounts in the complaint and the motion.
The detailed version
- SeaCube Containers LLC v. PT Lintas Kumala Abadi · No. 1:19-cv-10201
- Alvin Hellerstein
- Feb. 3, 2020
Background
SeaCube brought a breach-of-contract action against PT Lintas. The alleged contract required PT Lintas to lease ocean containers from SeaCube for use on or with ocean-going vessels that PT Lintas owns or operates. PT Lintas did not appear or defend the case, and the court issued a certificate of default.
SeaCube moved for a default judgment under Federal Rule of Civil Procedure 55. The court explained that when a defendant defaults, the defendant is treated as admitting the complaint’s well-pleaded allegations for purposes of liability. But the damages alleged in the complaint are not automatically treated as true. The court must review the evidence and determine the damages amount with reasonable certainty.
Information Required
The court required SeaCube, within two weeks after the order’s issuance, to submit:
- A copy of the lease identified in the complaint, along with any later amendments and renewals.
- Attorney time records supporting the requested $14,706 in attorney fees. The court noted that fee applicants generally must provide contemporaneous records showing, for each attorney, the date, hours worked, and nature of the work.
- An explanation for differences between the complaint and the default-judgment motion. The complaint requested $785,000 as the replacement value of the shipping containers and $520,278 in unpaid lease amounts. The motion and supporting affidavit requested $843,408 as the replacement value and $511,351.88 in unpaid lease amounts.
The court cited the rule that a default judgment cannot differ in kind from, or exceed in amount, what the pleadings demand.
Ruling
The order required additional information before the court could enter a default judgment calculating damages against PT Lintas. It did not state that the court entered or denied the default judgment. Judge Alvin K. Hellerstein signed the order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.