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Jones v. Hunt

District of Columbia Court of Appeals
Dec 20, 1972
298 A.2d 220 (D.C. 1972)

Summary

reversing denial of Rule 60(b) motion where defendant had been served by publication, the sufficiency of which the court declined to address, but did not receive actual notice, did not act in bad faith to evade service, and plaintiff showed no actual prejudice due to delay

Summary of this case from McLaughlin v. Fidelity Sec. Life Ins

Opinion

No. 6655.

Argued November 8, 1972.

Decided December 20, 1972.

Appeal from the Superior Court of the District of Columbia, Tim Murphy, J.

Raymond A. Yost, Washington, D.C., for appellant. Robert E. Anderson, Washington, D.C., also entered an appearance for appellant.

Alexander L. Benton, Washington, D.C., with whom Frank R. Cook, Jr., Washington, D.C., was on the brief, for appellee.

Before REILLY, Chief Judge, and FICKLING and YEAGLEY, Associate Judges.


Appellant questions the correctness of the denial of her motion to vacate default judgment and to quash service of process. We hold that the motions judge abused his discretion in denying the motion. We do not reach the other issue of lack of jurisdiction since a verified answer was filed with the motion by appellant.

See 6 C.J.S. Appearances § 12f (1937). We also note that no issue is raised concerning the timeliness of the motion.

On April 14, 1970, appellant and appellee were involved in a motor vehicle collision in the intersection of Firth Sterling Avenue and Howard Road, S.E., Washington, D.C. The accident was investigated by the Metropolitan Police Department and appellant was ticketed for failure to yield the right-of-way. The accident report listed appellant's address as 3510 18th Street, S.E., Washington, D.C.

On December 10, 1970, appellee filed suit in the District of Columbia Court of General Sessions (now Superior Court of the District of Columbia). Service was attempted at the 18th Street address but was ineffective because appellant had moved.

Appellee subsequently discovered that appellant's insurance carrier had filed an SR 21 form with the Safety Responsibility Section of the Department of Motor Vehicles listing her address as 23 Spruce Street, Chambersburg, Pennsylvania. Service was then attempted by registered mail pursuant to D.C. Code 1967, § 40-423. The letter was returned marked "Addressee Unknown; Moved Left no Address." An order of publication was obtained pursuant to D.C. Code 1967, § 13-336. After the third publication, a default was entered on November 1, 1971, and default judgment was entered on December 3, 1971, in the amount of $4,500.

On April 25, 1972, appellant filed a motion to vacate default judgment and to quash service of process which was accompanied by a verified answer and an unopposed affidavit. According to her affidavit, she lived at 3510 18th Street, S.E., Washington, D.C., at the time of the accident; that, subsequent to the accident, she moved to 60 Diamond Avenue, Fayetteville, Pennsylvania; that on or about August 1971 she moved to 1042 Oxalis Avenue, Orlando, Florida; and that she has never been served with suit papers nor has she in any manner received notice of this law suit. The motions judge, after argument of counsel, denied the motion without giving any reasons.

We note that no transcript or statement of proceedings and evidence was filed.

It is firmly established that the grant or denial of a motion to vacate default judgment under Superior Court Civil Rule 60(b)(6) is committed to the sound discretion of the trial judge, but this court has long recognized that even a slight abuse of discretion in refusing to set aside a judgment may justify reversal. The rationale behind this standard of review is that courts universally favor a trial on the merits. However, each case must be evaluated in light of its own particular facts after consideration of the following factors: did the movant (1) have actual notice of the proceeding; (2) act in good faith; (3) present a prima facie adequate defense; and (4) act promptly. Prejudice to the non-moving party should also be considered. Barr v. Rhea Radin Real Estate, Inc., D.C.App., 251 A.2d 634 (1969).

Barr v. Rhea Radin Real Estate, Inc., D.C.App., 251 A.2d 634 (1969); Meadis v. Atlantic Constr. Supply Co., D.C. App., 212 A.2d 613 (1965); Manos v. Fickenscher, D.C.Mun.App., 62 A.2d 791 (1948).

In the instant case the record reveals that appellant never received notice of the suit. Likewise, it is not shown that appellant's moves were made in a bad faith attempt to avoid the process of the trial court. Furthermore, appellant's verified answer sets out circumstances which, if proved, will defeat appellee's claim. Finally, there is no showing that appellee's claim will be prejudiced by a trial on the merits and, in the absence of such a showing, it will be presumed that he will be able to prove his case at any time.

Therefore, we hold appellant's motion to set aside the default judgment should have been granted.

Reversed and remanded with instruction to set aside the default.


Summaries of

Jones v. Hunt

District of Columbia Court of Appeals
Dec 20, 1972
298 A.2d 220 (D.C. 1972)

reversing denial of Rule 60(b) motion where defendant had been served by publication, the sufficiency of which the court declined to address, but did not receive actual notice, did not act in bad faith to evade service, and plaintiff showed no actual prejudice due to delay

Summary of this case from McLaughlin v. Fidelity Sec. Life Ins

In Hunt, however, there was no showing that the movant received notice of the suit, nor did the record indicate that the movant acted in bad faith to avoid the process of the trial court.

Summary of this case from Tennille v. Tennille

In Jones, a case arising out of an automobile accident, our focus was properly on whether the plaintiff's claim would be prejudiced by a trial if the default judgment were set aside.

Summary of this case from Venison v. Robinson

In Hunt, there is no indication that the movant's failure to receive notice could be attributed to negligence or bad faith on her part, but there is substantial evidence of appellant's negligence in this case.

Summary of this case from Union Storage Co., Inc. v. Knight
Case details for

Jones v. Hunt

Case Details

Full title:Linda A. JONES, Appellant, v. Thomas R. HUNT, Appellee

Court:District of Columbia Court of Appeals

Date published: Dec 20, 1972

Citations

298 A.2d 220 (D.C. 1972)

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