AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

The case arose from injuries sustained by two plaintiffs when a balcony at an apartment complex owned by the defendant collapsed. The plaintiffs alleged physical injuries, pain and suffering, permanent disability, and economic losses. Their spouses claimed loss of consortium. The defendant was the property owner and landlord of the apartment where the incident occurred (paras 3-4).

Procedural History

• District Court, March 11, 1999: The trial court denied the defendant's motion to set aside the default judgment, concluding that the defendant failed to meet the "excusable neglect" standard under Rule 1-060(B)(1). A bench trial on damages awarded the plaintiffs $919,478.56 plus costs (paras 5-6).

Parties' Submissions

• Appellant (Defendant): Argued that the trial court erred in applying the stricter Rule 1-060(B) "excusable neglect" standard instead of the more lenient Rule 1-055(C) "good cause" standard. Claimed the default judgment was improperly entered as it did not include a determination of damages, making it non-final. Asserted a meritorious defense, including evidence of regular inspections showing no hazardous conditions (paras 7, 10, 27, 33).
• Appellees (Plaintiffs): Contended that the defendant's motion to set aside the default judgment was properly denied under Rule 1-060(B). Argued that the defendant failed to preserve the argument for applying Rule 1-055(C) and that the trial court's decision should stand (paras 8, 10).

Legal Issues

• Whether the trial court erred in applying the Rule 1-060(B) "excusable neglect" standard instead of the Rule 1-055(C) "good cause" standard to the motion to set aside the default judgment.
• Whether the default judgment entered by the trial court was final or non-final due to the lack of a damages determination.
• Whether the defendant demonstrated "good cause" to set aside the default under Rule 1-055(C).
• Whether the defendant was entitled to a jury trial on the issue of damages (paras 2, 7, 15, 35).

Disposition

• The Court of Appeals reversed the trial court's denial of the motion to set aside the default judgment and remanded the case for a trial on the merits (para 36).

Reasons

Per Bustamante J. (Pickard and Robinson JJ. concurring):

• The Court determined that the trial court improperly applied the stricter Rule 1-060(B) "excusable neglect" standard instead of the more lenient Rule 1-055(C) "good cause" standard. The default judgment was non-final because it did not include a determination of damages, making Rule 1-055(C) applicable (paras 15-21).
• The Court emphasized that Rule 1-055(C) requires a more liberal approach to setting aside defaults, favoring decisions on the merits. The defendant's one-day delay in filing the answer was due to a miscalculation by her insurance adjuster, which constituted negligence but not willful or contumacious conduct. This satisfied the "good cause" standard (paras 23-29).
• The defendant presented a meritorious defense, supported by evidence of regular inspections showing no hazardous conditions, which could potentially change the outcome of the case (para 33).
• The Court found no significant intervening equities that would render setting aside the default inequitable, particularly given the minimal delay caused by the defendant's late filing (para 34).
• The issue of whether the defendant was entitled to a jury trial on damages was rendered moot by the decision to set aside the default and remand for a trial on the merits (para 35).