Villalta v. JS Barkats, P.L.L.C.

Background

Villalta brought the action against JS Barkats, P.L.L.C. and Sunny Barkats, alleging quid pro quo sexual harassment. The opinion states that the defendants failed to participate in discovery, disregarded court orders, and engaged in conduct intended to delay or derail the litigation.

Earlier Default Judgment

Villalta moved to hold the defendants in default. The court granted that motion and entered a default judgment. A default judgment is a judgment entered when a party fails to defend the case; the opinion then referred the matter to Magistrate Judge Lehrburger to determine the damages to be awarded.

Damages Recommendation

Judge Lehrburger issued a report recommending the following awards:

- $24,352.85 in lost-wages damages, including prejudgment interest; - $350,000 for emotional harm; - $700,000 in punitive damages; - $128,056.74 in reasonable attorney’s fees; - $2,285.28 in costs; and - post-judgment interest at the rate set under 28 U.S.C. § 1961.

Neither party filed objections to the report. When no objections are filed, the district court may review the recommendation for clear error, meaning an obvious mistake in the record.

Ruling

Judge Ronnie Abrams found no clear error and adopted Judge Lehrburger’s report in its entirety. The court awarded all of the recommended amounts and post-judgment interest under 28 U.S.C. § 1961. The court also directed the Clerk of Court to mail a copy of the order to the defendants and close the case.

Classification

This is a procedural order because it awarded damages after a default judgment rather than resolving the underlying harassment allegations through a contested merits decision.