Augusta Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 F.2d 808 (4th Cir. 1988). · Go Syfert
Augusta Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 F.2d 808 (4th Cir. 1988). Cases Citing This Book View Copy Cite
504 citation events (400 in the last 25 years) across 44 distinct courts.
Strongest positive: Jane Doe v. Richard Roe (mdd, 2025-12-11)
Treatment trajectory · 1989 → 2026 · click a year to view as-of
1989 2007 2026
Top citers, strongest first. 50 distinct citers. How cited ↗
discussed Cited as authority (verbatim quote) Jane Doe v. Richard Roe
D. Maryland · 2025 · quote attribution · 1 verbatim quote · confidence high
a meritorious defense requires a proffer of evidence which would permit a finding for the defaulting party or which would establish a valid counterclaim.
discussed Cited as authority (verbatim quote) ServicePower, Inc. v. Smart Merchant, LLC
D. Maryland · 2023 · signal: see also · quote attribution · 1 verbatim quote · confidence high
the underlying concern is whether there is some possibility that the outcome after a full trial will be contrary to the result achieved by the default.
discussed Cited as authority (verbatim quote) Xerox Corporation v. Rimm Holdings, Inc
D. Maryland · 2022 · signal: see · quote attribution · 1 verbatim quote · confidence high
a meritorious defense requires a proffer of evidence which would permit a finding for the defaulting party or which would establish a valid counterclaim.
examined Cited as authority (verbatim quote) 68th Street Site Work Group v. Airgas, Inc. (3×) also: Cited as authority (rule), Cited "see"
D. Maryland · 2021 · signal: see · quote attribution · 1 verbatim quote · confidence high
as to prejudice, we perceive no disadvantage to augusta beyond that suffered by any party which loses a quick victory.
discussed Cited as authority (verbatim quote) Davis v. Uhh Wee, We Care Inc. (2×) also: Cited as authority (rule)
D. Maryland · 2020 · signal: see · quote attribution · 1 verbatim quote · confidence high
as to prejudice, we perceive no disadvantage to augusta beyond that suffered by any party which loses a quick victory.
examined Cited as authority (verbatim quote) MACREGEN, INC. v. BURNETTE (3×) also: Cited as authority (rule), Cited "see"
M.D.N.C. · 2020 · signal: see also · quote attribution · 1 verbatim quote · confidence high
a meritorious defense requires a proffer of evidence which would permit a finding for the defaulting party . . . .
examined Cited as authority (verbatim quote) Gonzalez v. Spunk Industries Inc (3×) also: Cited as authority (rule), Cited "see"
D. Maryland · 2019 · signal: see · quote attribution · 1 verbatim quote · confidence high
as to prejudice, we perceive no disadvantage to augusta beyond that suffered by any party which loses a quick victory.
discussed Cited as authority (verbatim quote) Thompson-Knuckles v. Thompson (2×) also: Cited as authority (rule)
S.D.W. Va · 2019 · signal: cf. · quote attribution · 1 verbatim quote · confidence high
showing awakened speed, defendant moved for relief within two weeks of the entry of judgment, well within the rule's rule 60(b) one-year limit.
examined Cited as authority (verbatim quote) McCain v. Educational Credit Management Corp. (In Re McCain) (3×) also: Cited as authority (rule)
Bankr. E.D. Va. · 2006 · signal: see also · quote attribution · 1 verbatim quote · confidence high
we perceive no disadvantage to the non-moving party beyond that suffered by any party which loses a quick victory.
discussed Cited as authority (verbatim quote) Varney v. Varney (2×) also: Cited as authority (rule)
4th Cir. · 1996 · quote attribution · 1 verbatim quote · confidence high
we perceive no disad- vantage . . . beyond that suffered by any party which loses a quick victory.
discussed Cited as authority (verbatim quote) In Re Cecil Carl Varney, Debtor. Cecil Carl Varney v. Angela Lea Varney (2×) also: Cited as authority (rule)
4th Cir. · 1996 · quote attribution · 1 verbatim quote · confidence high
we perceive no disadvantage ... beyond that suffered by any party which loses a quick victory.
discussed Cited as authority (quoted) CHAMBERS v. BROWN (2×) also: Cited as authority (rule)
M.D.N.C. · 2025 · signal: see also · quote attribution · 1 verbatim quote · confidence low
asking the court to enter a default on defendants couzzi, kluk and rodgers
discussed Cited as authority (rule) Extreme Driver Inc. v. L Fab Enterprises, LLC and Montana Post Driver, LLC
W.D. Va. · 2026 · confidence medium
“The - 4 - underlying concern is whether there is some possibility that the outcome after a full trial will be contrary to the result achieved by the default.” Augusta Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 F.2d 808, 812 (4th Cir. 1988) (cleaned up) (emphasis added).
discussed Cited as authority (rule) Jimmy Edward Tinsley v. Joseph W. Walters
W.D. Va. · 2026 · confidence medium
With respect to the second threshold requirement, courts have explained that a meritorious claim or defense “requires a proffer of evidence which would permit a finding for the [moving] party or which would establish a valid [claim].” Augusta Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 F.2d 808, 812 (4th Cir. 1988).
cited Cited as authority (rule) United States of America ex rel. J. Bryan Quesenberry v. Breaks Interstate Park Commission et al.
W.D. Va. · 2026 · confidence medium
Corp., 843 F.2d 808, 811 (4th Cir. 1988)).
cited Cited as authority (rule) Carroll Murray v. Trans Union, LLC
W.D.N.C. · 2026 · confidence medium
Md. 2024) (citing Augusta Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 F.2d 808, 812 (4th Cir. 1988)).
cited Cited as authority (rule) Roy Dove, Jr. v. Azul International Security Services, LLC, et al.
D. Maryland · 2026 · confidence medium
July 8, 2013) (citing Augusta Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 F.2d 808, 812 (4th Cir. 1988)) (emphasis in original); accord U.S. v. Signed Pers.
discussed Cited as authority (rule) In re: Frederick Sims McRae v. Matthew W. Cheney, Acting United States Trustee for Region Four
Bankr. E.D. Va. · 2026 · confidence medium
Rather, “[t]he underlying concern is . . . whether there is some possibility that the outcome . . . after a full trial will be contrary to the result achieved by the default.” Augusta Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 F.2d 808, 812 (4th Cir. 1988) (emphasis added) (quoting 10 C.
discussed Cited as authority (rule) Kimila Wooten, Darryl Balderson v. Phoenix Motor Inc., d/b/a Phoenix Motorcars; Phoenix Cars LLC, d/b/a Phoenix Motorcars; Phoenix Cars Employee Benefit Plan
D.S.C. · 2025 · confidence medium
Pro. 12, Phoenix Motor’s actual receipt of the Secretary of State’s acceptance of service on August 25, 2025, accounts for its delay at least in part. [Doc. 14-1.] Because the delay does not appear attributable to “any intent . . . to disregard or derail the legal process,” Propps, 2021 WL 4951930 , at *2, this factor weighs in favor of Phoenix Motor.2 Prejudice to Plaintiffs Plaintiffs cannot demonstrate prejudice where they face “no disadvantage . . . beyond that suffered by any party which loses a quick victory.” Augusta Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 …
cited Cited as authority (rule) Jotham Bethea v. Equifax Information Services, LLC, et al.
W.D.N.C. · 2025 · confidence medium
Md. 2024) (citing Augusta Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 F.2d 808, 812 (4th Cir. 1988)).
discussed Cited as authority (rule) United States of America v. Clara Ann Mason, DVM (2×)
S.D.W. Va · 2025 · confidence medium
United States v. Moradi, 673 F.2d 725, 727 (4th Cir. 1982); Augusta Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 F.2d 808, 812 (4th Cir. 1988) (citations omitted).
discussed Cited as authority (rule) Brian Jeffrey Hall, Jr. v. Halsted Financial Services/Fortiva (2×)
W.D. Va. · 2025 · confidence medium
A “meritorious defense” requires Halsted to “proffer . . . evidence which would permit a finding for the defaulting party.” Augusta Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 F.2d 808, 812 (4th Cir. 1998).
discussed Cited as authority (rule) Disability Rights Maryland, Inc. v. Dr. Meena Seshamani, et al.
D. Maryland · 2025 · confidence medium
Indeed, DRM seemingly neglects the requisite procedure in its desire for “a quick victory,” resulting in unnecessary expenditure of time and expense upon both the parties and the court.18 Cf. Augusta Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 F.2d 808, 812 (4th Cir. 1988) (discussing prejudice on a motion to set aside default judgment).
discussed Cited as authority (rule) Kenneth Lee Combs and Custom Quality Carpentry LLC d/b/a CQC Home v. Lane Boland and Remodeler Launch LLC d/b/a Remodel Commander
M.D.N.C. · 2025 · confidence medium
Here, it has done enough by simply proffering specific facts to suggest that the merits outcome would be “contrary to the result achieved by the default.” Augusta Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 F.2d 808, 812 (4th Cir. 1988) (quoting 10 Wright & Miller’s Federal Practice & Procedure § 2697 (2d ed. 1983)).
discussed Cited as authority (rule) Securities and Exchange Commission v. Daryl M. Davis
D. Maryland · 2025 · confidence medium
There is no prejudice to a plaintiff where the disadvantage is simply the “los[s] [of] a quick victory.” Augusta Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 F.2d 808, 812 (4th Cir. 1988).
discussed Cited as authority (rule) United States of America v. Clara Ann Mason, DVM
S.D.W. Va · 2025 · confidence medium
The Fourth Circuit explains, “[a] meritorious defense requires a proffer of evidence which would permit a finding for the defaulting party or which would establish a valid counterclaim.” Augusta Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 F.2d 808, 812 (4th Cir. 1988) (citations omitted).
discussed Cited as authority (rule) Keith E. Adams and Kim Adams, Trustees of the Adams Family Trust Dated December 17, 1998 v. Crab Du Jour of Lynchburg, Inc., et al. (2×)
W.D. Va. · 2025 · confidence medium
A “meritorious defense” requires Defendants to “proffer . . . evidence which would permit a finding for the defaulting party or which would establish a valid counterclaim.” Augusta Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 F.2d 808, 812 (4th Cir. 1998).
discussed Cited as authority (rule) Keith W. R. Lowe v. Jonathan Frame, Superintendent, Mount Olive Correctional Complex
S.D.W. Va · 2025 · confidence medium
The Court of Appeals has explained that “[t]he underlying concern” of this prong is “whether there is some possibility that the outcome . . . after a full trial will be contrary to the result achieved by the default.” Id. (quoting Augusta Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 F.2d 808, 812 (4th Cir. 1988) (additional citation omitted)).
discussed Cited as authority (rule) Cook v. Superior Assisted Living, LLC
D. Maryland · 2025 · confidence medium
Meritorious Defense “A meritorious defense requires a proffer of evidence which would permit a finding for the defaulting party or which would establish a valid counterclaim.” Augusta Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 F.2d 808, 812 (4th Cir. 1988).
cited Cited as authority (rule) Securities and Exchange Commission v. Lee
D. Maryland · 2025 · confidence medium
Sept. 21, 2016) (quoting Augusta Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 F.2d 808, 812 (4th Cir. 1988)).
discussed Cited as authority (rule) Rawls v. Keen
W.D. Va. · 2025 · confidence medium
“A meritorious defense requires a proffer of evidence which would permit a finding for the defaulting party or which would establish a valid counterclaim.” Augusta Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 F.2d 808, 812 (4th Cir. 1988) (per curiam).
discussed Cited as authority (rule) Schneider v. American Water Works Company, Inc.
S.D.W. Va · 2025 · confidence medium
“A meritorious defense requires a proffer of evidence which would permit a finding for the defaulting party or which would establish a valid counterclaim.” Augusta Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 F.2d 808, 812 (4th Cir. 1988) (citing Central Operating Co. v. Utility Workers of America, 491 F.2d 245 , 252 n. 8 (4th Cir.1974); Williams v. Blitz, 226 F.2d 463 (4th Cir.1955)). 5 Defendants contend that they have at least two meritorious defenses to suit, namely, (1) the Court’s lack of personal jurisdiction over American Water Works Company, Inc., a Delaware corpora…
discussed Cited as authority (rule) Lori Chavez-DeRemer v. Medical Staffing of America, LLC
4th Cir. · 2025 · confidence medium
To prevail, a movant must act in a timely fashion, demonstrate a lack of prejudice to the nonmoving party, and proffer a “meritorious defense.” See Augusta Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 F.2d 808, 811 (4th Cir. 1988).
discussed Cited as authority (rule) Lori Chavez-DeRemer v. Medical Staffing of America, LLC
4th Cir. · 2025 · confidence medium
To prevail, a movant must act in a timely fashion, demonstrate a lack of prejudice to the nonmoving party, and proffer a “meritorious defense.” See Augusta Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 F.2d 808, 811 (4th Cir. 1988).
discussed Cited as authority (rule) Washington v. Dotson
W.D. Va. · 2025 · confidence medium
A meritorious claim or defense “requires a proffer of evidence which would permit a finding for the [moving] party or which would establish a valid [claim].” Augusta Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 F.2d 808, 812 (4th Cir. 1988).
discussed Cited as authority (rule) Abanda v. OurBloc LLC
D. Maryland · 2025 · confidence medium
“A meritorious defense requires a proffer of evidence which would permit a finding for the □ defaulting party or which would establish a valid counterclaim.” Augusta Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 F.2d 808, 812 (4th Cir. 1988) (internal citation omitted) (emphasis added); see also Timilon Corp. v. Empowerment Just.
discussed Cited as authority (rule) Sauer Construction, LLC v. R and R Masonry, Inc. (2×) also: Cited "see"
D.S.C. · 2025 · confidence medium
“A meritorious defense requires a proffer of evidence which would permit a finding for the defaulting party or which would establish a valid counterclaim.” Augusta Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 F.2d 808, 812 (4th Cir. 1988); accord Caribbean Indus.
discussed Cited as authority (rule) Peterman v. RAMod Brewers, LLC
E.D.N.C. · 2025 · confidence medium
That is, when the party is blameless, his attorney’s negligence qualifies as a ‘mistake’ or as ‘excusable neglect’ under Rule 60(b)(1).”) (cleaned up) (quoting Augusta Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 F.2d 808, 811 (4th Cir. 1988)).
discussed Cited as authority (rule) Denison v. Horsey Denison Landscaping LLC
D. Maryland · 2025 · confidence medium
There is no prejudice to a plaintiff where the disadvantage is simply the “los[s] [of] a quick victory.” Augusta Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 F.2d 808, 812 (4th Cir. 1988).
discussed Cited as authority (rule) Pacelli v. FREEJUMPSYSTEM
W.D. Va. · 2025 · confidence medium
Va. Mar. 16, 2004) (quoting Augusta Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 F.2d 808, 812 (4th Cir. 1988)). “[E]ven a tenuous defense may suffice so long as a court can discern the possibility that a defendant may vindicate his claim.” Id. (internal quotation marks omitted).
discussed Cited as authority (rule) America Science Team Richmond, Inc. v. Chan
E.D. Va. · 2025 · confidence medium
Instead, the party must merely make “a proffer of evidence which would permit a finding for the defaulting party.” August Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 F.2d 808, 812 (4th Cir. 1988).
discussed Cited as authority (rule) South Carolina CVS Pharmacy, L.L.C. v. SCP 2001A-CSF-75 LLC
D.S.C. · 2025 · confidence medium
“The underlying concern is . . . whether there is some possibility that the outcome . . . after a full trial will be contrary to the result achieved by the default.” Augusta Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 F.2d 808, 812 (4th Cir. 1988) (alterations in original) (internal quotation marks omitted).
discussed Cited as authority (rule) South Carolina CVS Pharmacy, L.L.C. v. SCP 2001A-CSF-72 LLC
D.S.C. · 2025 · confidence medium
“The underlying concern is . . . whether there is some possibility that the outcome . . . after a full trial will be contrary to the result achieved by the default.” Augusta Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 F.2d 808, 812 (4th Cir. 1988) (alterations in original) (internal quotation marks omitted).
discussed Cited as authority (rule) Atinus Works, LLC v. Green Clean, Inc.
D. Maryland · 2025 · confidence medium
“A meritorious defense requires a proffer of evidence which would permit a finding for the defaulting party or which would establish a valid counterclaim.” Augusta Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 F.2d 808, 812 (4th Cir. 1988).
discussed Cited as authority (rule) Billings v. Overton
E.D.N.C. · 2025 · confidence medium
Dismiss [DE #22] at 5–7); , 812 F. Supp. 2d at 724 (“In order for a defense to be meritorious, the proffer of evidence must only be one ‘which would permit a finding for the defaulting party . . . .’” (quoting , 843 F.2d 808, 812 (4th Cir. 1988))).
discussed Cited as authority (rule) The Talaria Company, LLC v. Duplessie
D. Maryland · 2024 · confidence medium
A. Meritorious Defense To establish a meritorious defense, the defaulting party must make a “a proffer of evidence which would permit a finding for the defaulting party or which would establish a valid counterclaim.” Augusta Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 F.2d 808, 812 (4th Cir. 1988); see also Acosta v. Vera’s White Sands Beach Club, LLC, No. 16-cv-782-PX, 2019 WL 1767147 , at *2 (D.
discussed Cited as authority (rule) Thornsberry v. Arkansas Department of Correction
E.D. Ark. · 2024 · confidence medium
“Whether a meritorious defense exists is determined by examining ‘whether the proffered evidence would permit a finding for the defaulting party.’” Stephenson v. El-Batrawi, 524 F.3d 907, 914 (8th Cir. 2008) (quoting Johnson, 140 F.3d at 785 ). “’The underlying concern is . . . whether there is some possibility that the outcome . . . after a full trial will be contrary to the result achieved by the default.’” Id. (quoting (quoting Augusta Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 F.2d 808, 812 (4th Cir.1988) (per curiam)).
discussed Cited as authority (rule) Mester v. MJC America, Ltd.
D. Maryland · 2024 · confidence medium
There is no prejudice to Plaintiffs where the disadvantage is simply the “los[s] [of] a quick victory.” Augusta Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 F.2d 808, 812 (4th Cir. 1988).
discussed Cited as authority (rule) Buechler v. Jones
D.S.D. · 2024 · confidence medium
Meritorious Defense A meritorious defense exists when “the proffered evidence ‘would permit a finding for the defaulting party.”” Bear v. Jumper No, 23-5083, 2024 WL 4348289 at *2 (D.S.D Sept. 30, 2024) (citing Johnson, 140 F.3d at 785 (noting the evidence does not have to be undisputed) (quoting Augusta Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 F.2d 808, 812 (4th Cir. 1988))).
cited Cited as authority (rule) Cook v. Superior Assisted Living, LLC
D. Maryland · 2024 · confidence medium
Augusta Fiberglass Coatings, Inc. v. Fodor Contracting Corp., 843 F.2d 808, 811 (4th Cir. 1988).
Retrieving the full opinion text from the archive…
AUGUSTA FIBERGLASS COATINGS, INC., Plaintiff-Appellee,
v.
FODOR CONTRACTING CORPORATION, Defendant-Appellant
87-2551.
Court of Appeals for the Fourth Circuit.
Apr 7, 1988.
843 F.2d 808
1988 U.S. App. LEXIS 4386
1988 WL 29890
Daniel F. Steinmetz, Jr., Pennsauken, N.J. (John William Weeks, Johnson, Johnson, Maxwell, Whittle, Shelgrove & Weeks, Aiken, S.C., on brief), for defendant-appellant., John Williams Harte, Jr., Aiken, S.C., for plaintiff-appellee.
Hall, Wilkinson, Bullock, Middle.
Cited by 274 opinions  |  Published
1 passage pin-cited by 1 case
Pinpoint authority: bottom 68%
Citer courts: M.D. North Carolina (1)
PER CURIAM:

The major issue presented by this appeal is whether the district court abused its discretion under Fed.R.Civ.P. 60(b) by denying a motion to vacate a default judgment. We conclude that the district court failed to apply the correct legal standard and that the default judgment should have been set aside.

I.

Fodor Contracting Corporation (“Fo-dor”), a New Jersey corporation, was the general contractor for the installation of odor-control equipment at the Cape May County Municipal Utilities Authority composting facility in New Jersey. Augusta Fiberglass Coatings, Inc. (“Augusta”) is a South Carolina corporation which bid on the subcontract for plastic tanks and duct work. Fodor accepted Augusta’s bid on March 13, 1986.

In late August a dispute arose over the nonpayment of Augusta’s invoices, which totaled approximately $300,000.00. Augusta sought a subcontractor’s lien in New Jersey, forcing Fodor to post a bond with the municipal utilities authority before Fo-dor could receive further payments. On September 18,1986, Augusta filed a breach of contract suit in United States District Court for the District of South Carolina.

Fodor referred the matter to attorney Daniel F. Steinmetz, Jr., who had already corresponded with Augusta’s attorney, John W. Harte, concerning Augusta’s lien claim. Attorneys Steinmetz and Harte quickly negotiated a partial settlement under which Fodor was to pay $194,000.00, Augusta was to reduce its New Jersey lien[*810] accordingly and to take a voluntary dismissal in its suit, and the parties would further negotiate the remaining claim of $110,-000.00. This settlement was memorialized in a letter from Harte to Steinmetz dated September 26, 1986 (one day after Fodor received the complaint and summons).

Fodor made the agreed-upon payment and the companies continued to negotiate their differences. The further negotiations broke down, however, and Augusta concluded that legal action was still required. Rather than taking a voluntary dismissal, Augusta merely amended its claim to reflect the $194,000.00 payment by Fodor. Harte mailed the amended complaint to Steinmetz on October 15, 1986, and Steinmetz received it on October 20. In his cover letter enclosing the amended complaint, Harte explained Augusta’s position and stated:

In light of the Fodor position it is evident that we still have a problem which requires court action. I have, therefore, amended the complaint to reflect the payment by Fodor. I see no reason to end the action since I would simply file a new action immediately. I enclose and serve upon you the amended complaint.

Harte wrote another letter to Steinmetz on October 24, 1986, which discussed the invoices Harte was compiling for Steinmetz’s review, described the damage Fo-dor’s nonpayment was causing, and threatened to “add these damages to the pending suit.” Despite these statements in Harte’s letters and the service of the amended complaint, Steinmetz believed that the negotiations had been revived and erroneously assumed that Harte would notify him before applying for a default judgment. Consequently, Fodor did not file an answer to Augusta’s complaint or amended complaint.

On November 11, 1986, forty-seven (47) days after service of the original complaint and twenty-six (26) days after mailing of the amended complaint, Harte filed an affidavit of default. On November 13, the clerk entered a default judgment against Fodor in the sum of $114,141.42. Steinmetz received a copy of this judgment on November 21, 1986, and Fodor moved to vacate the judgment on November 28. In its motion Fodor also challenged Augusta’s service of process and the court’s personal jurisdiction. In support of the motion, Steinmetz submitted an affidavit outlining the sequence of events and explaining his error. He also submitted affidavits from officers of Fodor which gave Fodor’s position in the dispute and detailed several counterclaims against Augusta.

After hearing argument in chambers, the district court entered an order dated February 19, 1987, which denied the motion to vacate. After discussing the adequacy of service of process and determining that it had personal jurisdiction, the district court denied relief because it found no excusable neglect as required by Rule 60(b). The district court held that Fodor “was the author of its own demise” through “its inactivity and failure to respond.” While we agree that jurisdiction was proper, we reverse the denial of Rule 60(b) relief because the district court failed to distinguish between the failure or neglect of Fodor’s attorney and the neglect of Fodor itself.

II.

Rule 60(b) is the means by which a court may relieve a party from a final judgment based on one of six grounds, the primary ground being “mistake, inadvertence, surprise, or excusable neglect.” Where defaults and judgments thereon are at issue, Rule 60(b) must be read with due regard for Rule 55(c), which provides that “for good cause shown, the court may set aside an entry of default, and, if a judgment by default has been entered, may likewise set it aside in accordance with Rule 60(b).” Rule 60(b) motions are addressed to the sound discretion of the district court and “ ‘will not be disturbed on appeal absent a showing of abuse of that discretion.’ ” Park Corp. v. Lexington Ins. Co., 812 F.2d 894, 896 (4th Cir.1987) (quoting Werner v. Carbo, 731 F.2d 204, 206 [4th Cir.1984]). However, where default judgments are at issue, over the years this court has taken an increasingly liberal view of Rule 60(b) which indicates that a reversal is warranted under the present circumstances.

[*811] This liberal view of discretionary relief from default judgments is best illustrated by United States v. Moradi, 673 F.2d 725 (4th Cir.1982). Moradi involved a defendant whose answer was rejected for noncompliance with local rules. No new answer was filed and a default judgment was granted after the defendant’s attorney failed to appear at a pre-trial conference. Relying on the defendant’s prompt motion for relief and his allegations of a meritorious defense, this court set aside the default judgment under Rule 60(b). Drawing a clear line between the fault of counsel and the fault of a party personally, we stated that “justice ... demands that a blameless party not be disadvantaged by the errors or neglect of his attorney.” 673 F.2d at 728. Noting that less severe sanctions were available, the Moradi court held that any doubt as to the propriety of giving relief must be resolved in the movant’s favor when the movant bears no personal responsibility for the error which led to the default. Id. Accord Lolatchy v. Arthur Murray, Inc., 816 F.2d 951 (4th Cir.1987) (default judgment imposed as a sanction for discovery abuses and disregard of court orders reversed because defendants were blameless and lesser sanctions were available); Educational Services, Inc. v. Maryland State Board for Higher Education, 710 F.2d 170, 177 (4th Cir.1983) (if default judgment had been granted for defendant’s failure to answer, under Moradi the district court “would have been virtually compelled” to set it aside upon a Rule 60[b] motion).

Moradi should be contrasted with Park Corp. v. Lexington Ins. Co., the one recent case involving a default judgment in which we have affirmed the denial of Rule 60(b) relief. In Park an insurer received process in its mailroom and inexplicably lost the papers. No attorney was contacted and no answer was filed, which eventually resulted in a default judgment. Without mentioning Moradi, Park employed a stricter analysis similar to the district court’s in this case. Although the insurer clearly had a meritorious defense, we held that it had failed to show excusable neglect, or any excuse at all, for its failure to answer; therefore it was not entitled to relief. Park, 812 F.2d at 897.

Although Park does not cite or discuss Moradi, the results of these two cases are entirely consistent when one considers that in Park the party alone was responsible for its default, whereas in Moradi the attorney alone was responsible for the default. While Moradi does not mention “excusable neglect” or any of the other grounds for relief under Rule 60(b), its import is that, when the party is blameless, his attorney’s negligence qualifies as a “mistake” or as “excusable neglect” under Rule 60(b)(1). Moreover, both cases require a movant to act in a timely fashion, to avoid unfair prejudice to the non-movant, and to proffer a meritorious defense in order to obtain relief. Park, 812 F.2d at 897; Moradi, 673 F.2d at 728.

This focus on the source of the default represents an equitable balance between our preference for trials on the merits and the judicial system’s need for finality and efficiency in litigation. When the party is blameless and the attorney is at fault, the former interests control and a default judgment should ordinarily be set aside. When the party is at fault, the latter interests dominate and the party must adequately defend its conduct in order to show excusable neglect. In all cases, a Rule 60(b) movant must act in a timely fashion, must demonstrate a lack of prejudice to the non-movant, and must proffer a meritorious defense. Park, 812 F.2d at 897; Moradi, 673 F.2d at 728. Finally, as noted under Moradi, when a default judgment is vacated the trial court may nonetheless impose other sanctions against the offending attorney, such as awarding the non-movant’s costs and attorney’s fees incident to the Rule 60(b) motion.

Applying these principles to the present case, the district court erred because it failed to distinguish between the fault of Fodor’s attorney and the fault, if any, of Fodor itself. Without discussing Fodor’s diligence in moving for relief or the merit of Fodor’s proffered defenses, the district court lumped Fodor and its attor[*812] ney together in finding that “the defendant is the author of its own demise.” Moreover, upon a thorough review of the record, we are convinced that Fodor is largely blameless for the default below, which was due primarily to its attorney’s carelessness in his handling of the amended complaint. Augusta corresponded exclusively with the attorney once he entered the negotiations; the amended complaint, its cover letter, and the letter of October 24 were all mailed directly to the attorney. The attorney’s affidavit establishes that he believed no answer was required; thus it would be unrealistic and unfair to expect his client to think otherwise. It was the attorney who assumed that his counterpart would give a commendable but unrequired notice before seeking the default judgment. Under these circumstances, “justice also demands that a party not be disadvantaged by the errors or neglect of his attorney.” Moradi, 673 F.2d at 728.

Under Moradi and Park, however, in order to merit relief Fodor still must demonstrate that it acted promptly, that Augusta will not suffer unfair prejudice if the default judgment is set aside, and that Fodor has a meritorious defense. Park, 812 F.2d at 897; Moradi, 673 F.2d at 728. There is little doubt that Fodor has satisfied the first two requirements. Showing awakened speed, Fodor moved for relief within two weeks of the entry of the judgment, well within the rule’s one-year limit. As to prejudice, we perceive no disadvantage to Augusta beyond that suffered by any party which loses a quick victory. Further, Fodor has secured Augusta by posting a bond in the full amount of Augusta’s claim. Augusta points to the difference between the legal interest rate and the rate it is charged by its financiers, but this unfortunate differential is borne by all such plaintiffs.

The presence of a meritorious defense is a tougher issue, but one that also must be resolved in Fodor’s favor. A meritorious defense requires a proffer of evidence which would permit a finding for the defaulting party or which would establish a valid counterclaim. Central Operating Co. v. Utility Workers of America, 491 F.2d 245, 252 n. 8 (4th Cir.1974); Williams v. Blitz, 226 F.2d 463 (4th Cir.1955). “The underlying concern is ... whether there is some possibility that the outcome ... after a full trial will be contrary to the result achieved by the default.” 10 C. Wright, A. Miller & M. Kane, Federal Practice and Procedure § 2697, p. 531 (2d ed. 1983). The affidavits of Fodor’s officers establish just such a possibility. In sum, these affidavits support the following defenses and counterclaims: (1) Fodor charges that approximately $40,000.00 of Augusta’s claim is due to additional work and material needed because of Augusta’s own errors; (2) Fodor alleges that it is due a back charge of $14,646.07 for its efforts to correct Augusta’s mistakes; (3) due to time delays, Fodor may be liable on a $500.00 per day liquidated damages clause, a liability it would in turn attempt to charge to Augusta; and (4) Fodor believes that Augusta wrongly filed its New Jersey lien claim and thus is responsible for the $5,000.00 Fodor expended in posting the bond to cover that claim. Although these statements address the amount, rather than the propriety, of Augusta’s claim, we believe that taken together they are a sufficient proffer of a meritorious defense. This conclusion is reinforced by Moradi’s admonition that any doubts should be resolved in the movant’s favor.

In sum, since Fodor acted promptly, demonstrated a lack of prejudice to Augusta, and proffered a meritorious defense, Fodor met its burden to justify relief under Rule 60(b). Although the district court is in the best position to weigh the competing interests implicated by default judgments within the context of each case, the district court’s failure to distinguish between a blameless party and its neglectful attorney constitutes legal error amounting to an abuse of discretion. Upon remand, the district court should allow Fodor to file its answer promptly and may consider the pro[*813] priety of other sanctions against its attorney.

REVERSED AND REMANDED.