default judgment rule (Utah) · Go Syfert
← Utah issues

default judgment rule in Utah

13 Utah opinions name it 2 courts 2003–2020 0 in the last five years

The cases below were cited by Utah courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (8)

CaseFollowedCited
Swallow v. Kennardgreen
utahctapp · 2008 · cited in 3 Utah opinions naming this issue, 2012–2012
2 sentences

2012But "while the district court's discretion to grant relief under rule 60(b) for excusable neglect is broad, it is not unlimited." Jones, 2009 UT 39, ¶ 20 , 214 P.3d 859 (emphasis added). "[E]xcusable neglect requires some evidence of diligence in order to justify relief." Id.; see also Swallow v. Kennard, 2008 UT App 134, ¶ 23 , 183 P.3d 1052 ("The supreme court has previously defined `excusable neglect' as `the exercise of "due diligence" by a reasonably prudent person under similar circumstances.'" (quoting Mini Spas, Inc. v. Industrial Comm'n, Dep't of Emp't Sec., 733 P.2d 130, 132 (Utah 19

2012But "while the district court's discretion to grant relief under rule 60(b) for excusable neglect is broad, it is not unlimited." Jones, 2009 UT 39, ¶ 20 , 214 P.3d 859 (emphasis added). "[E]xcusable neglect requires some evidence of diligence in order to justify relief." Id.; see also Swallow v. Kennard, 2008 UT App 134, ¶ 23 , 183 P.3d 1052 ("The supreme court has previously defined `excusable neglect' as `the exercise of "due diligence" by a reasonably prudent person under similar circumstances.'" (quoting Mini Spas, Inc. v. Industrial Comm'n, Dep't of Emp't Sec., 733 P.2d 130, 132 (Utah 19

33
Mini Spas, Inc. v. Industrial Commission of Utah, Department of Employment Securitygreen
utah · 1987 · cited in 3 Utah opinions naming this issue, 2012–2012
2 sentences

2012But “while the district court’s discretion to grant relief under rule 60(b) for excusable neglect is broad, it is not unlimited.” Jones, 2009 UT 39, ¶ 20 (emphasis added). “[E]xcusable neglect requires some evidence of diligence in order to justify relief.” Id.; see also Swallow v. Kennard, 2008 UT App 134, ¶ 23 , 183 P.3d 1052 (“The supreme court has previously defined ‘excusable neglect’ as ‘the exercise of “due diligence” by a reasonably prudent person under similar circumstances.’” (quoting Mini Spas, Inc. v. Industrial Comm’n, Dep’t of Emp’t Sec., 733 P.2d 130, 132 (Utah 1987) (per curiam

2012But "while the district court's discretion to grant relief under rule 60(b) for excusable neglect is broad, it is not unlimited." Jones, 2009 UT 39, ¶ 20 , 214 P.3d 859 (emphasis added). "[E]xcusable neglect requires some evidence of diligence in order to justify relief." Id.; see also Swallow v. Kennard, 2008 UT App 134, ¶ 23 , 183 P.3d 1052 ("The supreme court has previously defined `excusable neglect' as `the exercise of "due diligence" by a reasonably prudent person under similar circumstances.'" (quoting Mini Spas, Inc. v. Industrial Comm'n, Dep't of Emp't Sec., 733 P.2d 130, 132 (Utah 19

33
Helgesen v. Inyangumiagreen
utah · 1981 · cited in 2 Utah opinions naming this issue, 2013–2013
2 sentences

2013As we have previously emphasized, "discretion should be exercised in furtherance of justice and should incline towards granting relief ... to the end that the party may have a hearing." Helgesen v. Inyangumia, 636 P.2d 1079, 1081 (Utah 1981).

2013As we have previously emphasized, “discretion should be exercised in furtherance of justice and should incline towards granting relief . . . to the end that the party may have a hearing.” Helgesen v. Inyangumia, 636 P.2d 1079, 1081 (Utah 1981).

22
Menzies v. Galetkagreen
utah · 2006 · cited in 9 Utah opinions naming this issue, 2012–2020
2 sentences

2020“A district court has broad discretion to rule on a motion to set aside a default judgment under rule 60(b) of the Utah Rules of Civil Procedure.” Menzies v. Galetka, 2006 UT 81, ¶ 54 , 150 P.3d 480 .

2020“A district court has broad discretion to rule on a motion to set aside a default judgment under rule 60(b) of the Utah Rules of Civil Procedure.” Menzies v. Galetka, 2006 UT 81, ¶ 54 , 150 P.3d 480 .

19
Jones v. Layton/Oklandgreen
utah · 2009 · cited in 3 Utah opinions naming this issue, 2012–2012
2 sentences

2012But "while the district court's discretion to grant relief under rule 60(b) for excusable neglect is broad, it is not unlimited." Jones, 2009 UT 39, ¶ 20 , 214 P.3d 859 (emphasis added). "[E]xcusable neglect requires some evidence of diligence in order to justify relief." Id.; see also Swallow v. Kennard, 2008 UT App 134, ¶ 23 , 183 P.3d 1052 ("The supreme court has previously defined `excusable neglect' as `the exercise of "due diligence" by a reasonably prudent person under similar circumstances.'" (quoting Mini Spas, Inc. v. Industrial Comm'n, Dep't of Emp't Sec., 733 P.2d 130, 132 (Utah 19

2012But "while the district court's discretion to grant relief under rule 60(b) for excusable neglect is broad, it is not unlimited." Jones, 2009 UT 39, ¶ 20 , 214 P.3d 859 (emphasis added). "[E]xcusable neglect requires some evidence of diligence in order to justify relief." Id.; see also Swallow v. Kennard, 2008 UT App 134, ¶ 23 , 183 P.3d 1052 ("The supreme court has previously defined `excusable neglect' as `the exercise of "due diligence" by a reasonably prudent person under similar circumstances.'" (quoting Mini Spas, Inc. v. Industrial Comm'n, Dep't of Emp't Sec., 733 P.2d 130, 132 (Utah 19

13
Lund v. Browngreen
utah · 2000 · cited in 1 Utah opinions naming this issue, 2006–2006
2 sentences

2006See Lund v. Brown, 2000 UT 75, ¶ 9 , 11 P.3d 277 ; Russell v. Martell, 681 P.2d 1193, 1194 (Utah 1984); State Dep't of Soc.

2006See Lund v. Brown, 2000 UT 75, ¶ 9 , 11 P.3d 277 ; Russell v. Martell, 681 P.2d 1193, 1194 (Utah 1984); State Dep't of Soc.

11
Russell v. Martellgreen
utah · 1984 · cited in 1 Utah opinions naming this issue, 2006–2006
2 sentences

2006See Lund v. Brown, 2000 UT 75, ¶ 9 , 11 P.3d 277 ; Russell v. Martell, 681 P.2d 1193, 1194 (Utah 1984); State Dep't of Soc.

2006See Lund v. Brown, 2000 UT 75, ¶ 9 , 11 P.3d 277 ; Russell v. Martell, 681 P.2d 1193, 1194 (Utah 1984); State Dep't of Soc.

11
Erickson v. Schenkers International Forwarders, Inc.green
utah · 1994 · cited in 1 Utah opinions naming this issue, 2003–2003
1 sentence

2003See Erickson, 882 P.2d at 1149 (determining that there was a "restoration of the status quo ante” when two of the three requirements were satisfied under the “excusable neglect” standard for setting aside a default judgment under rule 60 of the Utah Rules of Civil Procedure).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Utah. Read the followed side critically anyway.

Also cited on this issue (3)

CaseCitedYears
Rojas v. Montoya green
utahctapp · 2020
1 sentence

2020Therefore, Swanson’s attempt to have judgment against her set aside on the ground of excusable neglect rises and falls with the actions of Montoya. 20180497-CA 16 2020 UT App 153 Rojas v. Montoya district court has broad discretion to rule on a motion to set aside a default judgment under rule 60(b) of the Utah Rules of Civil Procedure.”). 13 B.

12020–2020
Migliore v. Livingston Financial, LLC green
utah · 2015
2 sentences

2020“But the district court has no discretion with respect to a void judgment because the determination that a judgment is void implicates the court’s jurisdiction.” Migliore v. Livingston Fin., LLC, 2015 UT 9, ¶ 25 , 347 P.3d 394 .

2020“But the district court has no discretion with respect to a void judgment because the determination that a judgment is void implicates the court’s jurisdiction.” Migliore v. Livingston Fin., LLC, 2015 UT 9, ¶ 25 , 347 P.3d 394 .

12020–2020
Pioneer Investment Services Co. v. Brunswick Associates Ltd. Partnership green
scotus · 1993
2 sentences

2006Id. at 397 , 113 S.Ct. 1489 . ¶ 77 The situation is vastly different, however, when an attorney willfully disregards a client's interests, acts in a grossly negligent fashion, or renders ineffective assistance of counsel.

2006Id. at 397 , 113 S.Ct. 1489 . ¶ 77 The situation is vastly different, however, when an attorney willfully disregards a client's interests, acts in a grossly negligent fashion, or renders ineffective assistance of counsel.

12006–2006

Where else courts name it

TX 113 (1977–2025) OH 22 (1996–2026) UT 13 (2003–2020) CA 13 (1949–2022) AZ 10 (1969–2024) MO 10 (1977–2022) IA 10 (1965–2025) WA 9 (2007–2025) FL 7 (1923–2018) NC 7 (2005–2022) GA 6 (1962–2022) MN 6 (1965–2016) AL 6 (1979–2010) NY 5 (1962–2013) MT 5 (1990–2026) IL 5 (1971–2024) LA 5 (1987–2024) TN 4 (2002–2025) VT 4 (2002–2026) NJ 4 (2002–2024) HI 3 (2001–2022) SD 3 (1997–2024) WI 3 (1995–2025) NM 3 (1984–1996) AR 3 (1998–2024) MS 3 (2000–2002) PA 3 (1978–2018) VI 3 (2014–2017) DC 2 (1976–1981) CT 2 (1995–2012) OR 2 (1996–2010) MI 2 (1981–2023) CO 2 (2006–2026) ID 2 (1992–2008) MD 2 (1999–2018)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

← Caselaw search · G Cite Topics · Brief Check