Walden Solar PA Jefferson LLC v. Barbieri Land Management LLC
2:25-cv-00083
W.D. Pa.Apr 14, 2025Background
- Walden Solar PA Jefferson LLC and Barbieri Land Management LLC entered into a 2020 agreement for Walden to lease property in Jefferson County, PA, to develop solar power equipment, with an initial three-year term and options to renew.
- Walden timely exercised a renewal option in December 2024, but Barbieri failed to execute the renewal documents, breaching the agreement.
- The Court previously granted a preliminary injunction requiring Barbieri to execute the lease due to likely success on Walden’s breach of contract claim and irreparable harm to Walden.
- Barbieri executed the lease after the injunction but did not participate in the lawsuit or respond to Walden’s complaints or court orders.
- The Clerk entered default due to Barbieri’s lack of engagement, and Walden moved for default judgment including permanent injunctive and declaratory relief, dropping claims for damages, fees, and costs.
- The Court reviewed whether default judgment and the scope of requested relief were proper, ultimately granting Walden the requested injunctive and declaratory relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Breach of Contract | Barbieri failed to execute lease renewal as agreed | No participation | For Walden |
| Permanent Injunctive Relief | Walden will suffer harm without compliance | No participation | Granted to Walden |
| Declaratory Judgment (Rights under Lease) | Declaration needed to enforce rights | No participation | Declared in Walden's favor |
| Scope of Relief under Fed. R. Civ. P. 54(c) | Relief sought is consistent with pleadings | No participation | Relief granted as requested |
Key Cases Cited
- City of New York v. Mickalis Pawn Shop, LLC, 645 F.3d 114 (2d Cir. 2011) (describes the two-step process for default judgment under Rule 55)
- Chamberlain v. Giampapa, 210 F.3d 154 (3d Cir. 2000) (sets out factors for granting default judgment)
- Simbraw, Inc. v. United States, 367 F.2d 373 (3d Cir. 1966) (corporate entities must appear via counsel)
- Lampe v. Xouth, Inc., 952 F.2d 697 (3d Cir. 1991) (personal jurisdiction obtained by service under Rule 4)