Reported / Citable
Background
Bank of New York Mellon Trust Company, N.A., as trustee for Mortgage Assets Management Series I Trust, moved for a default judgment against multiple defendants. District Judge Kathleen Cardone referred that motion to Magistrate Judge Robert F. Castañeda for a report and recommendation.
The court found the bank’s briefing unclear as to whether the court had personal jurisdiction over five defendants: Norma Alicia Schreckengost, Veronica Guadalupe Stocker, Sylvia Yolanda Facio, Carol Facio Rivera, and Martin Manuel Facio.
The Court’s Holding
The court did not decide the merits of the default-judgment motion. Instead, it ordered the bank to file supplemental briefing by August 21, 2026, addressing whether the court has personal jurisdiction over the five identified defendants.
The order emphasized that a federal court must independently confirm subject-matter and personal jurisdiction before entering default judgment. A court lacking personal jurisdiction cannot enter a valid judgment against a defendant, and the party invoking federal jurisdiction bears the burden of establishing it when jurisdiction is at issue.
Key Takeaways
- A court must examine personal jurisdiction before entering default judgment.
- The plaintiff must establish personal jurisdiction over each defendant targeted by a default judgment.
- If the bank does not supplement its briefing, the magistrate judge will recommend denying the default-judgment motion without prejudice.
Why It Matters
The order underscores that a defendant’s failure to appear does not eliminate the jurisdictional prerequisites for a default judgment. Plaintiffs seeking default relief against multiple defendants should provide defendant-specific facts supporting personal jurisdiction.
This was a procedural order, not a final resolution of the bank’s motion or its claims.