Washington Metropolitan Area Transit Commission v. Reliable Limousine Service, LLC

Facts

Rodberg (D) operated several iterations of a limousine business from 1996 to 2009. Rodberg (D) operated Reliable Limousine, Inc. (RLI). RLI repeatedly failed to pay its federal taxes. When the IRS caught him, D simply shifted his limousine business to a new company: Reliable Limousine Service, LLC. It operated from 2009 to 2011 but failed to pay taxes. The IRS chased D down but D again shifted his business to a new company: Reliable Limousine and Bus Service, LLC. The United States sued D and his entities in the District of Maryland, seeking injunctive relief to force their compliance with the tax laws. D was held in contempt for 'willfully and deliberately' refusing to participate in discovery. D and the United States ultimately settled. D's businesses also transported passengers within the District without a license. P sued D and his current company seeking an injunction to shut down D's limousine operation. P served D with interrogatories and document requests with a deadline of November 2012. D never responded. In December, the district court ordered D to participate in discovery, extended the discovery deadline to January 2013, and set the case for trial in March 2013. D did not comply. D claimed he was at that point applying for a license. In February 2013, the district court rejected the excuse and sanctioned D by awarding P a default judgment. The default judgment included a permanent injunction that prohibited D and one of his entities from transporting passengers for hire in the District. D simply switched to another incarnation of his business. P returned to court seeking a contempt citation. In October 2013, the court issued an order expressly placing the latest incarnation of the business under the February 2013 injunction's prohibition on transporting passengers for hire. D appealed. 

Issues

Rule of Law

Holding and Decision

Legal Analysis

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