default judgment hearing (Washington) · Go Syfert
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default judgment hearing in Washington

9 Washington opinions name it 2 courts 2007–2025 4 in the last five years

The cases below were cited by Washington 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 (2)

CaseFollowedCited
Morin v. Burrisgreen
wash · 2007 · cited in 5 Washington opinions naming this issue, 2013–2025
2 sentences

2025See Morin v. Burris, 160 Wn.2d 745, 756 , 161 P.3d 956 (2007) (“appearance in court to resist a motion to convert a temporary restraining order into an injunctive was a general appearance entitling the defendant to notice of the default judgment hearing”).

2025“A party who has appeared in an action is entitled to notice of a default judgment hearing and, if no notice is received, is generally entitled to have judgment set aside without further inquiry.” 6 No. 40157-0-III Lamb v. Lamb Morin v. Burris, 160 Wn.2d 745, 754 , 161 P.3d 956 (2007) (construing the notice requirement of CR 55(a)(3)).

35
Morin v. Burrisgreen
wash · 2007 · cited in 4 Washington opinions naming this issue, 2024–2025
2 sentences

2025See Morin v. Burris, 160 Wn.2d 745, 756 , 161 P.3d 956 (2007) (“appearance in court to resist a motion to convert a temporary restraining order into an injunctive was a general appearance entitling the defendant to notice of the default judgment hearing”).

2025“A party who has appeared in an action is entitled to notice of a default judgment hearing and, if no notice is received, is generally entitled to have judgment set aside without further inquiry.” 6 No. 40157-0-III Lamb v. Lamb Morin v. Burris, 160 Wn.2d 745, 754 , 161 P.3d 956 (2007) (construing the notice requirement of CR 55(a)(3)).

24

Distinguished, questioned or overruled (0)

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

Also cited on this issue (6)

CaseCitedYears
Tiffin v. Hendricks green
wash · 1954
2 sentences

2014A party that has appeared in an action but is not served with notice of a motion for default is entitled to have a default judgment set aside "as a matter of right," and the court "has no discretion to exercise on the question of whether the judgment should be set aside." Tiffin v. Hendricks, 44 Wn.2d 837, 847 , 271 P.2d 683 (1954).

2014A party that has appeared in an action but is not served with notice of a motion for default is entitled to have a default judgment set aside "as a matter of right," and the court "has no discretion to exercise on the question of whether the judgment should be set aside." Tiffin v. Hendricks, 44 Wn.2d 837, 847 , 271 P.2d 683 (1954).

32007–2014
Dlouhy v. Dlouhy green
wash · 1960
2 sentences

2007Dlouhy, 55 Wash.2d at 722 , 349 P.2d 1073 .

2007Dlouhy, 55 Wn.2d at 722 .

22007–2007
White v. Holm green
wash · 1968
2 sentences

2007Nor has either established mistake, surprise, or excusable neglect as required by White, 73 Wash.2d at 352 , 438 P.2d 581 , or inequitable conduct as required by Trickel, 52 Wash. 13 , 100 P. 155 .

2007Nor has either established mistake, surprise, or excusable neglect as required by White, 73 Wn.2d at 352 , or inequitable conduct as required by Trickel, 52 Wash. 13 .

22007–2007
State ex rel. Trickel v. Superior Court green
wash · 1909
2 sentences

2007Nor has either established mistake, surprise, or excusable neglect as required by White, 73 Wash.2d at 352 , 438 P.2d 581 , or inequitable conduct as required by Trickel, 52 Wash. 13 , 100 P. 155 .

2007Nor has either established mistake, surprise, or excusable neglect as required by White, 73 Wn.2d at 352 , or inequitable conduct as required by Trickel, 52 Wash. 13 .

22007–2007
Conner v. Universal Utilities green
wash · 1986
1 sentence

2024Conner, 105 Wn.2d at 172 .

12024–2024
In re the Estate of Stevens green
washctapp · 1999
1 sentence

2019Id.

12019–2019

Statutes the citing opinions construe

WA § Wash. Rev. Code § 4.28.210 (6)

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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