Neufville v. Metro Community Health Centers, Inc.

Background

On May 25, 2023, the court granted Neufville’s motion for default judgment against Metro Community Health Centers, Inc. as to liability on her ERISA claim. The court did not yet determine the amount of damages. It ordered Neufville to submit materials explaining the basis for the requested award and a discrepancy in the amount requested. After granting Neufville an extension, the court ordered the defendant to show cause in writing why damages should not be awarded. The defendant did not respond.

Damages Review

The court conducted an inquiry into damages using only Neufville’s affidavits and documentary submissions. It explained that a plaintiff seeking damages after a default judgment must provide enough evidence to establish the amount with reasonable certainty. A hearing was not required because damages could be determined from detailed written evidence, and neither party requested a hearing.

Neufville requested compensation for lost earnings, interest, attorney’s fees, and costs. Her affidavit stated that she had earned $73 per hour for approximately 16 hours per week and had lost approximately 30 weeks of pay after her discharge in February 2022. The court granted her request for $35,040.00 in back pay. It also granted her requests for $1,829.09 in interest, $3,000.00 in attorney’s fees under 29 U.S.C. § 1132(g), and $582.00 in costs.

The court noted that Neufville’s submissions contained another calculation error. Adding the amounts awarded produced a total of $40,451.09, rather than the $40,051.19 stated in one request.

Disposition

The court ordered judgment entered in Neufville’s favor against Metro Community Health Centers, Inc. for $40,451.09 in damages, interest, attorney’s fees, and costs. The court requested that the clerk close the case.