Montefiore Medical Center v. Teamsters Local, 272

Background

Montefiore Medical Center brought two actions against Local 272 Welfare Fund and its manager, Marc Goodman. Montefiore sought payment for medical services it provided to Fund beneficiaries. The first action was filed in 2009, and the second was filed in 2014.

In February 2019, the court awarded Montefiore prejudgment interest at the federal prime rate for a subset of claims identified as its post-MagnaCare Employee Retirement Income Security Act (ERISA) claims from the two actions. The court directed Montefiore to submit proposed interest calculations to Magistrate Judge Sarah Netburn for approval.

Report and Recommendation

On August 25, 2020, Judge Netburn issued a Report and Recommendation advising the court to award Montefiore simple prejudgment interest of $309,069.65. Neither party objected.

When no objection is filed, the district court may review a magistrate judge’s recommendation for clear error on the record. The opinion states that failing to object may also waive appellate review when the recommendation provided that warning.

Ruling

Judge Ronnie Abrams reviewed Judge Netburn’s recommendation for clear error, found none, and adopted it in its entirety. The court awarded Montefiore $309,069.65 in prejudgment interest, directed the Clerk of Court to terminate the pending motions, enter judgment, and close the two cases.