Jsc Transmashholding v. Miller
264 F. Supp. 3d 201
| D.D.C. | 2017Background
- JSC Transmashholding (plaintiff) and James F. Miller (defendant) executed a written Settlement Agreement on Nov. 20, 2014 resolving plaintiff’s prior suit for $600,000 plus interest.
- Under the Agreement Miller acknowledged a Total Amount (principal plus interest) but could pay a discounted scheduled monthly repayment plan: $5,000/month (12 months), $10,000/month (next 12 months), then $15,000/month until paid.
- Agreement required monthly payments on the first of each month; an Event of Acceleration would occur if a payment was more than 15 days late and plaintiff provided written notice, making the full Total Amount immediately due and payable.
- Miller paid through August 1, 2016, then failed to make payments due Sept.–Dec. 2016 and Jan. 1, 2017. Plaintiff gave written notice of acceleration on Dec. 2, 2016 and sued on Jan. 4, 2017.
- Miller filed an answer but did not meaningfully oppose plaintiff’s summary judgment motion and expressly chose not to pursue defenses in his response to the court’s show-cause order.
- District Court granted plaintiff’s motion for summary judgment, found the Agreement enforceable, found breach by nonpayment, awarded judgment for the outstanding Total Amount ($599,282.56 as of Jan. 4, 2017), and required plaintiff to file an affidavit calculating prejudgment interest; requests for postjudgment interest and fees were held in abeyance.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Enforceability of Settlement Agreement | Agreement is a valid, definite contract setting payment schedule and interest; governs performance. | Miller disputed allegations generally but declined to press defenses; did not contest enforceability. | Agreement is enforceable under D.C. contract law. |
| Breach of contract | Miller stopped paying installments (Sept. 2016–Jan. 2017); acceleration notice was given, so full amount became due. | No substantive opposition or exculpatory explanation pursued. | Miller breached by failing to pay; plaintiff entitled to damages. |
| Calculation of outstanding amount | Total Amount increased per contract interest terms; plaintiff’s calculation showed $599,282.56 due as of Jan. 4, 2017. | No meaningful challenge to the calculation. | Court accepted plaintiff’s figure as the outstanding Total Amount. |
| Prejudgment and postjudgment interest; fees and costs | Plaintiff seeks prejudgment and postjudgment interest at 8% (per contract) and attorneys’ fees/costs. | No meaningful opposition; court noted federal law governs postjudgment interest. | Prejudgment interest mandatory under D.C. Code §15-108; plaintiff must file affidavit with calculation. Postjudgment interest and fees/costs deferred — plaintiff may move with supporting documentation. |
Key Cases Cited
- Holcomb v. Powell, 433 F.3d 889 (D.C. Cir. 2006) (summary judgment standard and viewing evidence for nonmovant)
- Reeves v. Sanderson Plumbing Prods., 530 U.S. 133 (U.S. 2000) (standard on evaluating evidence in summary judgment context)
- Anderson v. Liberty Lobby, 477 U.S. 242 (U.S. 1986) (summary judgment and reasonable inferences for nonmovant)
- Winston & Strawn, LLP v. McLean, 843 F.3d 503 (D.C. Cir. 2016) (movant retains burden to show entitlement to summary judgment; court must perform Rule 56 analysis)
- Dyer v. Bilaal, 983 A.2d 349 (D.C. 2009) (enforceability of settlement agreements under contract principles)
- Dist. Cablevision Ltd. v. Bassin, 828 A.2d 714 (D.C. 2003) (prejudgment interest under D.C. Code §15-108 required when debt is liquidated and interest payable by contract)
