Vasquez-Padilla v. Medco Properties, LLC, 8:16-cv-03740

Plaintiff Ruben Vasquez-Padilla (Delaware citizen) alleges he slipped on ice in the Golden Corral parking lot in Salisbury, Maryland on February 16, 2014, sustaining injuries and claiming $350,000 in past and future damages.
Defendants Medco Properties, LLC and Potomac Foods Company-II, Inc. are Maryland companies that owned/operated the restaurant.
Plaintiff was served properly; defendants did not answer, and the Clerk entered default on April 5, 2017.
Plaintiff moved for default judgment on May 24, 2017.
The Court evaluated whether the Complaint pleaded sufficiently specific facts (beyond labels and conclusions) to establish negligence under Maryland law, in particular notice to defendants of the icy condition.
The Court denied the motion for default judgment without prejudice, vacated the Clerk’s entry of default, and gave Plaintiff 14 days to amend the complaint to cure deficiencies or face dismissal with prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether entry of default judgment is warranted where defendants did not respond	Vasquez-Padilla contends default judgment is proper because defendants were served and are unresponsive	Defendants made no submission (no defenses asserted)	Denied: court exercised discretion to deny default judgment because complaint lacks well‑pleaded facts on key elements
Whether the complaint sufficiently pleads negligence under Maryland law	Plaintiff alleges defendants knew or had notice of ice in the parking lot causing his fall	No responsive pleading; court assesses adequacy under Twombly/Iqbal standards	Complaint fails: allegations of notice are conclusory and lack factual detail needed to show actual or constructive notice
Whether well‑pleaded factual allegations (other than damages) are presumed true on default	Plaintiff relies on acceptance of well‑pleaded allegations when defendant defaults	Default admits well‑pleaded factual allegations, but not conclusory labels	Court treats only well‑pleaded facts as admitted and rejects mere labels/conclusions; here allegations were not well‑pleaded
Remedy and further procedures after denial	Plaintiff seeks entry of judgment now	Defendants remain unresponsive	Court denied default judgment, vacated default, and allowed 14 days to amend complaint or face dismissal

Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading must contain factual content plausibly showing entitlement to relief)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (complaint must allege enough facts to state a plausible claim)
SEC v. Lawbaugh, 359 F. Supp. 2d 418 (D. Md. 2005) (default judgment is within the court’s discretion)
Ryan v. Homecomings Fin. Network, 253 F.3d 778 (4th Cir. 2001) (default admits well‑pleaded factual allegations except damages)
United States v. Shaffer Equip. Co., 11 F.3d 450 (4th Cir. 1993) (Fourth Circuit policy favors deciding cases on the merits)
Park Corp. v. Lexington Ins. Co., 812 F.2d 894 (4th Cir. 1987) (default judgment upheld where defendant failed to respond)
Baltimore Line Handling Co. v. Brophy, 771 F. Supp. 2d 531 (D. Md. 2011) (applying Twombly/Iqbal standards in default judgment context)