Workplace Technologies Research, Inc. v. Project Management Institute, Inc.
- Proceeding
- district
- Area
- civil
- Panel
- Jinsook Ohta (author)
Analysis
Defendant PMI moved to approve a bond and stay enforcement of the judgment against it, and the plaintiff filed a notice of non-opposition. The court granted the motion, approved a bond in the amount of $3,179,500, and stayed enforcement of the judgment pending post-trial motions and appeals.
| What the court decided | The model |
|---|---|
Motion to Approve Bond and Stay Enforcement granted“PMI’s Motion is GRANTED and a bond in the amount of $3,179,500 is approved.” | agree with court The court applied the discretionary standard for supersedeas bonds under Rule 62(b). It noted that while the proposed bond amount was below the typical benchmark of 1.25 to 1.5 times the judgment, it was reasonable because the prevailing plaintiff did not oppose the motion and the parties agreed the amount might need to be revisited. The court’s decision to grant the stay based on the plaintiff's non-opposition and the specific circumstances of the case is a valid exercise of discretion. |
The order itself: sound — The order correctly identifies the legal standard for supersedeas bonds under Rule 62(b) and cites relevant Ninth Circuit and district court authorities regarding the purpose and typical amount of such bonds. The court explicitly acknowledges that the proposed bond amount is below the typical benchmark but provides specific, reasonable grounds for approving it anyway: the non-opposition of the prevailing party and the agreement of both parties that the amount may need to be revisited. The reasoning is complete and directly addresses the motion.
Opinion
l > . 3 4 5 6 . 7 UNITED STATES DISTRICT COURT 8 SOUTHERN DISTRICT OF CALIFORNIA _ 9 10 || WORKPLACE TECHNOLOGIES Case No.: 18cv1927 JO (MSB) 1 RESEARCH, INC., Plaintiff | ORDER ON MOTION TO APPROVE 12 "| BOND AND STAY ENFORCEMENT B 14 PROJECT MANAGEMENT INSTITUTE, (Doc. No. 421) INC., . 15 Defendant. 16 PROJECT MANAGEMENT INSTITUTE, 17 |INC., 18 Counter-Claimant, 19 20 || WORKPLACE TECHNOLOGIES RESEARCH, INC., Counter-Defendant. 22 23 24 Defendant Project Management Institute, Inc. (“PMI”) filed a Motion to Approve 25 ||Bond and Stay Enforcement. (Doc. No. 421). Plaintiff Workplace Technologies 26 || Research, Inc. (“WTRI’) filed a Notice of Non-Opposition. (Doc. No. 424). For the 27 |;reasons set forth below, PMI’s Motion is GRANTED. 28 □ 1 LEGAL STANDARD 2 Federal Rule of Civil Procedure 62 governs stays of proceedings to enforce 3 ||judgments. See Fed. R. Civ. P. 62. Under Federal Rule of Civil Procedure 62(b): At any time after judgment is entered, a party may obtain a stay 5 by providing a bond or other security. The stay takes effect 6 when the court approves the bond or other security and remains 7 in effect for the time specified in the bond or other security.
g “District courts have inherent discretionary authority in setting supersedeas bonds[.]’ 9 Rachel v. Banana Republic, Inc., 831 F.2d 1503, 1505 n.1 (9th Cir. 1987). 10 ANALYSIS 11 PMI requests that the Court stay enforcement of the judgment in this action on the condition of bond for $3,179,500—an amount equal to the judgment entered against PMI 13 (Doc. Nos. 413 at 2; 421-1 at 2). The Court must examine whether this bond amount is 14 sufficient to protect WTRI’s interests in collecting its judgment. 15 “The posting of a bond protects the prevailing plaintiff from the risk of a later 16 uncollectible judgment and compensates him for delay in the entry of the final 17 judgment.” NLRB v. Westphal, 859 F.2d 818, 819 (9th Cir. 1988); see also Rachel 18 831 F.2d at 1505 n.1. While Rule 62(b) is silent on the amount of bond required tc 19 Protect the prevailing party, courts have required bond amounts in the range of “1.25 tc 20 1.5 times the judgment.” Cotton v. City of Eureka, 860 F. Supp. 2d 999, 1029 (N.D. Cal 2012) (internal quotation marks omitted). Courts typically set a bond amount higher thar 27 the judgement because the amount is “intended to encompass the judgment, costs or 73 appeal, interest, and damages for delay.” Salinas v. Pac. Castle Newport I, LLC, No SACV 14-01233-CJC(ANx), 2016 U.S. Dist. LEXIS 194321, at *24 (C.D. Cal. Oct. 20 25 2016). Here, although PMI’s proposed bond amount is below the typical benchmark, the 47 ||court finds PMI’s request reasonable for two reasons. First, WTRI, the prevailing 28 plaintiff, does not oppose PMI’s motion. (Doc. No. 424). As bond requirements serve 1 ||the purpose of protecting the interests of the prevailing party, WTRI’s non-opposition ‘2 carries significant weight with the Court. Second, both Parties recognize the amount of 3 |}bond will likely need to be revisited pending the court’s resolution of the Parties’ post- 4 motions and any subsequent appeals. (Doc. Nos. 421-1 at 2 n.1; 424 at 2). 5 For the above reasons, PMI’s Motion is GRANTED and a bond in the amount of 6 $3,179,500 is approved. PMI is directed to file the original bond with the Clerk of Court 7 within fourteen days of the entry of this Order. Upon the filing of the bond, the 8 ||enforcement of the judgment in this case will be STAYED pending the resolution of the 9 ||Parties’ post-trial motions and any subsequent appeals. 10 If necessary, the court will revisit the amount of bond—after appropriate meet and 11 ||confer efforts and briefing from the Parties—at a later point in time following the Court’s 12 || disposition of the Parties’ post-trial motions. 13 IT IS SO ORDERED. 14 ||Dated: August 26, 2022 15 16 H insook Ohta 7 ed States District Judge 18 19 20 21 22 23 24 . 25 26 27 28