Gesualdi v. Quadrozzi Equipment Leasing Corp., 629 F. App'x 111

Trustees of Local 282 fringe-benefit Funds sued Quadrozzi Equipment Leasing Corp. and Amstel Recycling & Concrete Corp. under ERISA to collect unpaid contributions after a 2009 audit.
Complaint alleged Quadrozzi and Amstel were a single employer or alter egos, and was served; defendants proceeded pro se and engaged in settlement talks but failed to answer.
Clerk entered defaults on January 31, 2012; Trustees moved for default judgment and the district court entered a default judgment on December 12, 2012 for $1,613,008.66.
Defendants moved under Fed. R. Civ. P. 60(b)(1) to vacate the default judgment on April 23, 2013; the district court denied the motion on July 12, 2013 primarily as untimely.
The district court’s order did not analyze whether the complaint sufficiently alleged liability, whether defendants had meritorious defenses, or whether plaintiffs would be prejudiced by vacatur.
The Second Circuit vacated and remanded for the district court to address willfulness, meritorious defense, prejudice, and to explain its reasoning to permit meaningful appellate review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rule 60(b)(1) relief is warranted for the default judgment	Trustees: default judgment stands; defendants’ delay not excusable	Defendants: mistake/inadvertence/excusable neglect justifies vacatur	Remanded: district court must fully consider Rule 60(b)(1) factors and explain ruling
Whether the complaint sufficiently established liability on default	Trustees: well‑pleaded allegations support single‑employer/alter‑ego liability under ERISA	Defendants: challenged sufficiency and sought to litigate merits	District court did not rule on sufficiency; Second Circuit requires court to address this on remand
Whether defendants’ default was willful	Trustees: defendants knowingly failed to respond	Defendants: claimed confusion and intent to seek counsel; proceeded pro se	District court addressed willfulness but did not fully explain; remanded for fuller analysis
Whether vacating default would prejudice plaintiffs and whether defendants have meritorious defenses	Trustees: vacatur would prejudice collection and delay recovery	Defendants: asserted potential meritorious defenses to liability and damages	District court failed to assess prejudice and meritorious defenses; remanded to evaluate and explain

Finkel v. Romanowicz, 577 F.3d 79 (2d Cir. 2009) (district court must determine complaint alleges liability before entering default judgment)
City of New York v. Mickalis Pawn Shop, LLC, 645 F.3d 114 (2d Cir. 2011) (default admits well‑pleaded factual allegations)
State St. Bank & Tr. Co. v. Inversiones Errazuriz Limitada, 374 F.3d 158 (2d Cir. 2004) (articulates three‑factor test for vacating default judgment under Rule 60(b))
SEC v. McNulty, 137 F.3d 732 (2d Cir. 1998) (Rule 60(b) motions reviewed for abuse of discretion)
Ruotolo v. City of New York, 514 F.3d 184 (2d Cir. 2008) (standard of review for denial of Rule 60(b) relief)
New York v. Green, 420 F.3d 99 (2d Cir. 2005) (preference for resolving disputes on the merits; doubts resolved for party seeking relief)