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931 So. 2d 40

Sumlin v. Sumlin

Court of Civil Appeals of Alabama

Decided December 2, 2005

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Court of Civil Appeals of Alabama · decided 2005-12-02

Cited by 24 later decisions — most recently October 2018

24 state decisions

Key passage — most relied on by later courts

“"[A] trial court's broad discretionary authority under Rule 55(c) should not be exercised without considering the following three factors: 1) whether the defendant has a meritorious defense; 2) whether the plaintiff will be unfairly prejudiced if the default judgment is set aside; and 3) whether the default judgment was a result of the defendant's own culpable conduct."”

quoted by 3 later decisions, including Jarrett v. Federal National Mortgage Ass'n, 72 So. 3d 682 - Jarrett v. FEDERAL NAT. MORTG. ASS'N

“Furthermore, this court has previously stated that ' "we can envision no species of case in which the 'strong bias' in favor of reaching the merits ... could be any stronger than in a case such as this involving custody of a minor child.”

quoted by 1 later decision, including Wise v. Wise

Good law ✅— No negative treatment on recordhow we know

Decided 2005-12-02

View the full empirical analysis of this case →

¶1

¶2Upon further reflection, and consideration of the application for rehearing, I am now persuaded by the main opinion that a failure to demonstrate the second Kirtland factor is not the shattering blow to the wife's motion for relief from the default judgment, especially given the specific facts of this case. The main opinion has convinced me that where the ultimate issue to be decided is glaringly substantial to all parties involved, e.g., the custody of a minor child, the "balance of equities" tilts in favor of relief from the default judgment.

¶3

¶4I write specially to discuss an issue affecting the thirdKirtland factor: whether the default judgment was a result of the defendant's own culpable conduct.

¶5The defendant failed to utilize the Attorney Calendar Conflict Resolution Order which our Supreme Court adopted in 1990-15 years ago! This flagrant disrespect for court rules is culpable conduct weighing strongly against the defendant's motion for relief, except in a case such as this involving custody of a minor child.

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