Washington Metropolitan Area Transit Commission v. Reliable Limousine Service, LLC, 414 U.S. App. D.C. 1

Rodberg operated an unlicensed limousine business in the District and was sued by WMATC for injunctive relief.
Rodberg failed to participate in discovery in WMATC v. Reliable Limo. Serv., LLC, leading to a February 2013 default injunction against Rodberg and RLS.
Rodberg continued operations via RLBS, which led WMATC to seek further enforcement and contempt proceedings in the district court.
The district court issued a clarifying order in October 2013 to extend the injunction to RLBS, based on privity/relationship with Rodberg.
Rodberg appeals the February 2013 default injunction (Case No. 13-7072) and the October 2013 clarifying order (Case No. 13-7161), challenging both under the district court’s jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the default judgment sanction was an abuse of discretion	WMATC argues Rodberg’s willful discovery lapses justified default.	Rodberg contends the default is inappropriately harsh for a single or minor discovery lapse and seeks lesser sanctions.	No abuse; default affirmed.
Whether the October 2013 order was reviewable and whether RLBS was bound	WMATC argues the order clarifies existing injunctive scope to bind RLBS under Rule 65(d)(2).	Rodberg contends the October order modifies the injunction and is reviewable as a final/controlling order.	Court lacks jurisdiction to review; RLBS was already bound by the February injunction.

NHL v. Metro. Hockey Club, Inc., 427 F.2d 639 (1976) (establishes discovery sanctions standards and default judgments)
Webb v. Dist. of Columbia, 146 F.3d 964 (D.C. Cir. 1998) (abuses of discretion in settling discovery sanctions)
Founding Church of Scientology v. Webster, 802 F.2d 1448 (D.C. Cir. 1986) (requires explanation of sanctions, permits strong sanctions for willful misconduct)
Bristol Petrol. Corp. v. Harris, 901 F.2d 165 (D.C. Cir. 1990) (recognizes court’s discretion in sanctions and timing near trial)
Ripalda v. Am. Operations Corp., 977 F.2d 1464 (D.C. Cir. 1992) (single misconduct can justify dismissal under certain conditions)
Automated Datatron, Inc. v. Woodcock, 659 F.2d 1168 (D.C. Cir. 1981) (two warnings near trial can justify sanctions for noncompliance)
Philip Morris USA Inc. v. United States, 686 F.3d 839 (D.C. Cir. 2012) (tests whether an order actually modifies a prior injunction)
Regal Knitwear Co. v. NLRB, 324 U.S. 9 (1945) (injunctions bind privity and related entities to prevent evasion)
Roe v. Operation Rescue, 919 F.2d 857 (3d Cir. 1990) (extension of injunctions to those in active concert)
United States v. Schine, 260 F.2d 552 (2d Cir. 1958) (illustrates piercing or extending injunctions to related actors)
Vacco v. Operation Rescue Nat’l, 80 F.3d 64 (2d Cir. 1996) (considers scope of injunctions and related entities)