Beyond the Pleadings: Fifth Circuit Clarifies the Scope of Rule 54(c) and Rule 55(b) in Default-Judgment Awards
A Detailed Commentary on Hernandez v. Poveda, No. 24-20492 (5th Cir. Aug. 4, 2025)

1. Introduction

Hernandez v. Poveda is a consolidated appeal stemming from a Texas prison-force incident in 2016 that ultimately produced three separate determinations:

• an $800,000 default judgment against Officer Manuel Poveda, Jr.;
• a $780,000 jury verdict against Officer Edgar Razo; and
• a series of trial-level evidentiary rulings challenged on appeal.

While the Fifth Circuit affirmed every aspect of the district court’s handiwork, the opinion’s lasting significance lies in its treatment of Federal Rules of Civil Procedure 54(c) and 55(b). The court held that where the complaint prays for a numeric amount and open-ended categories such as “medical and legal expenses,” Rule 54(c) does not cap the default award at the numeric figure, provided the district court conducts the Rule 55(b)(2) hearing required for unliquidated damages. The decision also supplies guidance on double-recovery arguments, application of the Maximum Recovery Rule, and the use of Rule 37 to exclude late-disclosed witnesses.

2. Summary of the Judgment

The Fifth Circuit (Judges Wiener, Willett, and Ho, per curiam) affirmed:

1. the $800,000 default judgment against Poveda, rejecting claims of double recovery and Rule 54(c) violation;
2. the $780,000 jury award against Razo, finding it supported by substantial evidence and outside the Maximum Recovery Rule’s remit; and
3. all challenged evidentiary rulings, holding that any errors were either nonexistent or harmless.

3. Analysis

3.1 Precedents Cited and Their Influence

• Wooten v. McDonald Transit Assocs., Inc., 788 F.3d 490 (5th Cir. 2015) – standard of review for setting aside defaults.
• Richardson v. Salvation Army, 161 F.3d 7 (5th Cir. 1998) – requirement of hearings for unliquidated damages.
• James v. Frame, 6 F.3d 307 (5th Cir. 1993) & United Artists v. Freeman, 605 F.2d 854 (5th Cir. 1979) – necessity of evidentiary hearings.
• Stewart v. Thigpen, 730 F.2d 1002 (5th Cir. 1984) – deference to jury findings.
• Cowart v. Erwin, 837 F.3d 444 (5th Cir. 2016) – used to distinguish Maximum Recovery analysis.
• Pope v. Rollins Protective Servs. Co., 703 F.2d 197 (5th Cir. 1983) – “shocks the conscience” test for excessiveness.
• Longoria v. Hunter Express, 932 F.3d 360 (5th Cir. 2019) & Puga v. RCX Solutions, 922 F.3d 285 (5th Cir. 2019) – methodology for Maximum Recovery Rule.
• Foradori v. Harris, 523 F.3d 477 (5th Cir. 2008) – relevant jurisdiction constraint.

These authorities provided the scaffold for four doctrinal conclusions:

1. Default judgments are reviewed for abuse of discretion, with factual findings reviewed for clear error (Wooten).
2. Unliquidated damages require a Rule 55(b)(2) hearing (Richardson).
3. Jury awards stand unless “entirely disproportionate” (Pope, Stewart).
4. The Maximum Recovery Rule requires a factually similar Fifth Circuit precedent; lacking that, no remittitur (Longoria, Puga, Foradori).

3.2 The Court’s Legal Reasoning

3.2.1 Default Judgment & Rule 54(c)

Poveda argued Rule 54(c) capped damages at the $50,000 number explicitly pleaded. The panel disagreed, noting that Hernandez also pleaded for “legal and medical expenses,” making the total demand open-ended. Once a hearing was held under Rule 55(b)(2) – which did occur – the district court could rely on expert testimony and medical billing to determine a higher amount. The panel therefore clarified that the numeric ceiling in Rule 54(c) is not iron-clad when the pleading supplies broader categories that alert the defendant to the specific consequences of default.

3.2.2 Double Recovery

Because Poveda never appeared at trial, the jury charge explicitly excluded him. Consequently, the $780,000 jury award did not encompass injuries attributable to Poveda, and the default judgment created no duplicative compensation.

3.2.3 Jury Award & Maximum Recovery Rule

Razo’s attack on the $780,000 verdict failed for two reasons:

1. Substantial evidence existed – Hernandez’s testimony, medical records, photos, expert life-care plan of up to $861,049.
2. No Fifth Circuit case with comparable facts required reduction; Cowart differed materially in injury scope and damages categories.

3.2.4 Evidentiary Rulings

The court methodically applied Rules 403, 801–803, 106, and 701, concluding that any exclusion or admission either fit a hearsay exception, satisfied completeness, or was harmless. Of note, Rule 37(c)(1) justified excluding Assistant Warden Smith because he was disclosed only five weeks before trial and lacked first-hand knowledge.

3.3 Expected Impact of the Decision

• Default-Damages Practice – Litigants in the Fifth Circuit now have explicit confirmation that a complaint seeking a specific sum “plus medical/legal expenses” gives sufficient notice for awards higher than the stated sum if a Rule 55(b)(2) hearing fleshes out the evidence.
• Pleading Strategy – Plaintiffs should plead both a dollar figure and broad categories to preserve flexibility; defendants should appear if facing potentially large unliquidated components.
• Maximum Recovery Rule – The case raises the bar for defendants seeking remittitur; they must produce a nearly identical Fifth Circuit precedent, not district-court or unpublished cases.
• Trial Management – The opinion reinforces strict adherence to Rule 37 disclosures and cautions against late-stage witness additions.

4. Complex Concepts Simplified

• Default Judgment – A binding judgment entered when a defendant fails to respond. The court may still hold a mini-trial (Rule 55(b)(2)) to calculate unliquidated damages.
• Rule 54(c) Cap – Normally, a default award cannot exceed what the complaint demanded, but “demand” includes non-numeric categories expressly pleaded.
• Maximum Recovery Rule – An appellate doctrine allowing reduction of an excessive jury award to the highest amount sustainable by comparable precedents.
• Double Recovery – Receiving compensation twice for the same injury, which courts disallow. Segregated defendants/claims must be examined to avoid overlap.
• Rule 37 Witness Exclusion – If a party fails to timely list a witness under Rule 26, that witness is barred from testifying unless the omission is harmless or substantially justified.

5. Conclusion

Hernandez v. Poveda will be cited chiefly for its clarification that Rule 54(c)’s “must not exceed” language does not hamstring a district court where the pleadings seek both a specified sum and indeterminate categories of damages, and the court convenes the requisite Rule 55(b)(2) hearing. The Fifth Circuit’s comprehensive validation of the district court’s actions – from damage calculations to evidentiary rulings – underscores a broader message: procedural rules offer both swords and shields, but only to litigants who wield them diligently and on time. Future defendants facing the risk of default will now have heightened incentive to appear lest an “open-ended” prayer transform into a substantial judgment, while plaintiffs gain a roadmap for drafting complaints that preserve the full measure of potential relief.