Hartford Fire Insurance Company v. Queens County Carting Inc.
- Nelson Roman
- 7:20-cv-01844
- U.S. District Court · Southern District of New York
- 4
In Hartford Fire v. Queens County Carting, Judge Roman ordered judgments of $209,889 against Queens County Carting and $286,679.40 against QCC Maintenance.
Hartford Fire Insurance Company received judgments for $209,889.00 against Queens County Carting, Inc. and $286,679.40 against QCC Maintenance, Inc.; the action was closed.
What happened
In Hartford Fire Insurance Company v. Queens County Carting, Inc., Hartford claimed that Queens County Carting, Inc. and QCC Maintenance, Inc. failed to pay additional premiums owed under workers’ compensation insurance policies. The defendants did not answer, and the court had previously denied Queens County Carting’s request to cancel the default.
The court reviewed Hartford’s evidence, including final audits and bills showing the adjusted premiums owed. Under New York law, Hartford had to establish the damages with reasonable certainty. The court found that the evidence supported the amounts Hartford requested for its account-stated claim and that no damages hearing was necessary.
Judge Nelson S. Roman directed the Clerk of Court to enter judgment for Hartford against Queens County Carting, Inc. for $209,889.00 and against QCC Maintenance, Inc. for $286,679.40. The court also directed that the action be closed.
The detailed version
- Hartford Fire Insurance Company v. Queens County Carting Inc. · No. 7:20-cv-01844
- Nelson Roman
- Apr. 5, 2022
Background
Hartford Fire Insurance Company sued Queens County Carting, Inc. and QCC Maintenance, Inc. for breach of contract, accounts stated, and unjust enrichment. Hartford alleged that the defendants failed to pay premiums owed under workers’ compensation insurance policies. The defendants failed to answer, and the Clerk entered certificates of default on April 28, 2020. The court later denied Queens County Carting’s motion to vacate the default.
After a March 17, 2022 hearing, the court directed the parties to brief damages. Hartford’s supplemental brief focused on its account-stated claim and requested $209,889.00 from Queens County Carting and $286,679.40 from QCC Maintenance.
Legal standard
A default judgment establishes liability based on the well-pleaded allegations in the complaint, leaving damages as the remaining issue. The plaintiff must prove damages with reasonable certainty. Federal Rule of Civil Procedure 54(c) also requires that a default judgment not differ in kind from, or exceed in amount, the demand in the pleadings. Because the case was based on diversity jurisdiction, the court applied New York substantive law to damages.
Under New York law, an account stated requires a promise by a debtor to pay a stated amount that the parties agreed was due.
Damages analysis
Hartford submitted a supplemental declaration with final audits showing the total gross premiums owed by each defendant and final bills showing the adjusted premium amounts. The court found that these documents adequately established Hartford’s damages. Because the amounts were certain, the court concluded that a damages hearing was unnecessary.
Disposition
The Clerk of Court was directed to enter judgment in favor of Hartford Fire Insurance Company and against Queens County Carting, Inc. in the amount of $209,889.00, and against QCC Maintenance, Inc. in the amount of $286,679.40. The court also directed that the action be closed. Judge Nelson S. Roman signed the order on April 5, 2022.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.