default judgment challenge (Missouri) · Go Syfert
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default judgment challenge in Missouri

10 Missouri opinions name it 2 courts 1977–2022 1 in the last five years

The cases below were cited by Missouri 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 (7)

CaseFollowedCited
Xiaoyan Gu v. Da Hua Hu, and ACE INA Insurance Company Canada, Defendants/Respondents.green
moctapp · 2014 · cited in 2 Missouri opinions naming this issue, 2014–2014
2 sentences

2014Family Support Division v. Stovall-Reid, 163 S.W.3d 519, 521-22 (Mo.App.E.D.2005) ("[r ]es judi-cata prevents a party from re-litigating issues judicially determined in a previous action, even when the judgment was entered by default,” and notice of the default judgment hearing is not relevant where the default judgment has not been set aside and remains in effect) (italics added, and internal citation omitted); and Xiaoyan Gu v. Da Hua Hu, 447 S.W.3d 680, 690-91 (Mo.App.E.D.2014) (res judicata "applies to the parties and their privies," and ”[f]or privity to exist, ... the interests of the pa

2014E.D. 2005) (“[r]es judicata prevents a party from re-litigating issues judicially determined in a previous action, even when the judgment was entered by default,” and notice of the default judgment hearing is not relevant where the default judgment has not been set aside and remains in effect) (italics added, and internal citation omitted); and Xiaoyan Gu v. Da Hua Hu, No. ED100001, 2014 WL 3728710, at *8 (Mo.App.

22
Crouch v. Crouchgreen
mo · 1982 · cited in 2 Missouri opinions naming this issue, 2000–2001
2 sentences

2001LEGAL ANALYSIS We recognize that “a personal judgment rendered by a court without personal jurisdiction over the defendant is void and may be attacked collaterally” and that “a defendant ⅛ always free to ignore the judicial proceedings, risk a default judgment and then challenge that judgment on jurisdictional grounds in a collateral proceeding.’” Crouch v. Crouch, 641 S.W.2d 86, 90 (Mo. banc 1982) (quoting Ins.

2000As to Point Five (positing error based on lack of personal jurisdiction over Husband by the dissolution court), we are constrained to point out that we recognize that a “personal judgment rendered by a court without personal jurisdiction over the defendant is void and may be attacked collaterally,” Crouch v. Crouch, 641 S.W.2d 86, 90 (Mo. banc 1982); and that a defendant “ % always free to ignore the judicial proceedings, risk a default judgment and then challenge that judgment on jurisdictional grounds in a collateral proceeding.’ ” /¿.(quoting Insurance Corp. of Ireland v. Compagnie des Baux

22
Lindsey v. Lindseygreen
moctapp · 2011 · cited in 1 Missouri opinions naming this issue, 2019–2019
1 sentence

2019Id. “‘Rule 74.05 is inapplicable where a trial court strikes a party’s pleadings and enters judgment as a sanction for the party’s failure to comply with a discovery order.’” Id. (quoting Lindsey v. Lindsey, 336 S.W.3d 487, 492 (Mo.App.

11
Stine v. Warfordgreen
moctapp · 2000 · cited in 1 Missouri opinions naming this issue, 2014–2014
1 sentence

2014Family Support Division v. Stovall-Reid, 163 S.W.3d 519, 521-22 (Mo.App.E.D.2005) ("[r ]es judi-cata prevents a party from re-litigating issues judicially determined in a previous action, even when the judgment was entered by default,” and notice of the default judgment hearing is not relevant where the default judgment has not been set aside and remains in effect) (italics added, and internal citation omitted); and Xiaoyan Gu v. Da Hua Hu, 447 S.W.3d 680, 690-91 (Mo.App.E.D.2014) (res judicata "applies to the parties and their privies," and ”[f]or privity to exist, ... the interests of the pa

11
NATIONAL TAX ASSISTANCE CORPORATION v. Washingtongreen
moctapp · 2005 · cited in 1 Missouri opinions naming this issue, 2014–2014
1 sentence

2014Family Support Division v. Stovall-Reid, 163 S.W.3d 519, 521-22 (Mo.App.E.D.2005) ("[r ]es judi-cata prevents a party from re-litigating issues judicially determined in a previous action, even when the judgment was entered by default,” and notice of the default judgment hearing is not relevant where the default judgment has not been set aside and remains in effect) (italics added, and internal citation omitted); and Xiaoyan Gu v. Da Hua Hu, 447 S.W.3d 680, 690-91 (Mo.App.E.D.2014) (res judicata "applies to the parties and their privies," and ”[f]or privity to exist, ... the interests of the pa

11
Angle v. Owsleygreen
moctapp · 1959 · cited in 1 Missouri opinions naming this issue, 2000–2000
1 sentence

2000However, “the onus rests on petitioner to show lack of jurisdiction ... [by referencing] the record itself or ... in any way that is both proper and convincing.” Angle v. Owsley, 332 S.W.2d 457, 459 (Mo.App.1959).

11
Gibson Ex Rel. Woodall v. Elleygreen
moctapp · 1989 · cited in 1 Missouri opinions naming this issue, 1991–1991
1 sentence

1991See Gibson v. Elley, 778 S.W.2d 851, 854 (Mo.App.1989) (discussing the meaning of “recklessness” within the context of Rule 74.05).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (6)

CaseCitedYears
Insurance Corp. of Ireland v. Compagnie Des Bauxites De Guinee green
scotus · 1982
2 sentences

2000As to Point Five (positing error based on lack of personal jurisdiction over Husband by the dissolution court), we are constrained to point out that we recognize that a “personal judgment rendered by a court without personal jurisdiction over the defendant is void and may be attacked collaterally,” Crouch v. Crouch, 641 S.W.2d 86, 90 (Mo. banc 1982); and that a defendant “ % always free to ignore the judicial proceedings, risk a default judgment and then challenge that judgment on jurisdictional grounds in a collateral proceeding.’ ” /¿.(quoting Insurance Corp. of Ireland v. Compagnie des Baux

2000As to Point Five (positing error based on lack of personal jurisdiction over Husband by the dissolution court), we are constrained to point out that we recognize that a “personal judgment rendered by a court without personal jurisdiction over the defendant is void and may be attacked collaterally,” Crouch v. Crouch, 641 S.W.2d 86, 90 (Mo. banc 1982); and that a defendant “ % always free to ignore the judicial proceedings, risk a default judgment and then challenge that judgment on jurisdictional grounds in a collateral proceeding.’ ” /¿.(quoting Insurance Corp. of Ireland v. Compagnie des Baux

31982–2001
Erica Hollins v. Capital Solutions Investments I, Inc., d/b/a Loan Express Co. green
moctapp · 2015
2 sentences

2022Id. at 22 . 3 $729.90 in interest from the date the debtor defaulted until the date of the default judgment is in violation of the statute.

2022Id. at 29 .

12022–2022
Greasel Conversions, Inc. v. Massa green
moctapp · 2013
2 sentences

2019Id. “‘Rule 74.05 is inapplicable where a trial court strikes a party’s pleadings and enters judgment as a sanction for the party’s failure to comply with a discovery order.’” Id. (quoting Lindsey v. Lindsey, 336 S.W.3d 487, 492 (Mo.App.

2019Id. “‘Rule 74.05 is inapplicable where a trial court strikes a party’s pleadings and enters judgment as a sanction for the party’s failure to comply with a discovery order.’” Id. (quoting Lindsey v. Lindsey, 336 S.W.3d 487, 492 (Mo.App.

12019–2019
Sprung v. Negwer Materials, Inc. green
mo · 1987
2 sentences

1989If the problems in Sprung I, 727 S.W.2d 883 (Mo. banc 1987), and Barney v. Suggs, 688 S.W.2d 356 (Mo. banc 1985), could have been resolved by a petition in equity, there would have been no need to adopt a new default judgment rule.

1989If the problems in Sprung I, 727 S.W.2d 883 (Mo. banc 1987), and Barney v. Suggs, 688 S.W.2d 356 (Mo. banc 1985), could have been resolved by a petition in equity, there would have been no need to adopt a new default judgment rule.

11989–1989
Barney v. Suggs green
mo · 1985
2 sentences

1989If the problems in Sprung I, 727 S.W.2d 883 (Mo. banc 1987), and Barney v. Suggs, 688 S.W.2d 356 (Mo. banc 1985), could have been resolved by a petition in equity, there would have been no need to adopt a new default judgment rule.

1989If the problems in Sprung I, 727 S.W.2d 883 (Mo. banc 1987), and Barney v. Suggs, 688 S.W.2d 356 (Mo. banc 1985), could have been resolved by a petition in equity, there would have been no need to adopt a new default judgment rule.

11989–1989
JR Watkins Company v. Hubbard green
moctapp · 1961
1 sentence

1977Watkins Company v. Hubbard, 343 S.W.2d 189 (Mo.App.1961), and other cases cited by the respondent, petitioner’s counsel obtained the default judgment in violation of an agreement not to do so; again, the record clearly shows the contrary is true.

11977–1977

Statutes the citing opinions construe

MO § Mo. Rev. Stat. § 452.305 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

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.

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