Vista Food Exchange, Inc. v. Law

Background

On April 3, 2023, the Clerk entered a $3,133,627.31 judgment in favor of Vista Food Exchange, Inc. against Lawson Foods, LLC in a prior related proceeding. Vista then filed a motion under Federal Rule of Civil Procedure 59(e), which permits a court to alter or amend a judgment, asking the court to enter an amended judgment against Lawson Foods LLC, Simon Law, and Fortress Foods jointly and severally.

The court explained that Rule 59(e) relief may be granted when there has been a change in controlling law, newly available evidence, or a clear legal error or manifest injustice. The court also noted that such relief is an extraordinary remedy generally used sparingly.

Court’s Analysis

A magistrate judge had recommended that Lawson Foods LLC, Simon Law, and Fortress Foods be held jointly and severally liable for $2,258,537. The court adopted that recommendation and later issued an amended order finding Lawson Foods LLC liable for that amount. The court concluded that it had intended to adopt the recommendation in full but had accidentally omitted Simon Law and Fortress Foods from the judgment. It therefore found that the judgment contained an error.

Vista also asked the court to amend the judgment to enforce a separate contempt award entered in November 2019. That award required Lawson Foods LLC, Simon Law, and Fortress Foods to pay Vista $392,376, consisting of $314,576 in attorneys’ fees and $77,800 in daily contempt fines. The court stated that the defendants had not fully complied and that amending the judgment was appropriate to correct the error and prevent an unfair result.

Disposition

Judge Carter granted Vista’s motion to alter or amend the judgment. The court directed the defendants to pay the contempt award in full within 30 days, warning that they could face further civil contempt proceedings. The court dismissed Vista’s separate motion to expedite as moot and directed the Clerk to terminate both motions.