Colortree Group, LLC v. Autotrol Corporation

Background

Colortree Group, LLC sued Autotrol Corporation for breach of contract. According to the complaint, the parties entered into six transactions between May and July 2020 involving plastic bottles manufactured in China with foam or lotion pump heads. Autotrol accepted the shipments without objection but did not pay the full amounts listed in the invoices. The complaint alleged that Autotrol owed $601,508.06.

Autotrol was served with the complaint, but it did not appear or file an answer. The clerk entered a certificate of default. Colortree then moved for a default judgment, and Autotrol did not respond even after the court warned that the motion would be treated as unopposed.

Court’s analysis

A default judgment is a judgment entered when a defendant fails to plead or otherwise defend. Although a default accepts the complaint’s well-pleaded factual allegations as true, the court must still decide whether those allegations establish legal liability. The court concluded that Colortree’s allegations established Autotrol’s liability as a matter of law.

Colortree sought compensatory damages of $601,508.06. It expressly disclaimed prejudgment interest and attorney’s fees and sought only the $402.00 filing cost in addition to the unpaid balance.

Ruling

Judge J. PAUL OETKEN granted Plaintiff’s motion for default judgment. The court awarded Colortree a judgment against Autotrol for $601,508.06 plus $402.00, totaling $601,910.06. The court directed the clerk to enter judgment and close the case.

The opinion uses both “Colortree” and “Colorgroup” in referring to the plaintiff in different passages; this summary follows the captioned party name, Colortree Group, LLC.