Washington Metropolitan Area Transit Authority v. Reliable Limousine Service, L.L.C.

Paul Rodberg (defendant) operated an unlicensed limousine service under various business names in the District of Columbia from 1996 to 2013. Rodberg was sued by the Internal Revenue Service for failing to pay taxes, and in that litigation, Rodberg was held in contempt for failing to cooperate with discovery. In 2012 the Washington Metropolitan Area Transit Authority (WMATA) (plaintiff) sued Rodberg and his company, Reliable Limousine Service, L.L.C. (defendant), for operating his business without a license, seeking an injunction to shut down Rodberg’s business. Rodberg initially failed to respond to interrogatories, requiring the discovery deadline to be moved. The district court ordered Rodberg to cooperate with discovery efforts. Rodberg again refused to respond to interrogatories, asserting that he did not need to respond to interrogatories because he was applying for a license with the WMATA. Because the trial date was approaching and the WMATA had not been able to conduct discovery, the district court entered default judgment for the WMATA and permanently enjoined Rodberg from operating his limousine business. On appeal, Rodberg argued that the court should have imposed a less harsh sanction before entering a default judgment, and that a court cannot enter a default judgment after a single discovery violation.