Chrysler Financial Services Americas, LLC v. Betty Benjamin

CourtCourt of Appeals of Georgia
DecidedJanuary 21, 2014
DocketA13A2276
StatusPublished

This text of Chrysler Financial Services Americas, LLC v. Betty Benjamin (Chrysler Financial Services Americas, LLC v. Betty Benjamin) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Chrysler Financial Services Americas, LLC v. Betty Benjamin, (Ga. Ct. App. 2014).

Opinion

THIRD DIVISION ANDREWS, P. J., DILLARD and MCMILLIAN, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. http://www.gaappeals.us/rules/

January 21, 2014

In the Court of Appeals of Georgia A13A2276. CHRYSLER FINANCIAL SERVICES AMERICAS, LLC v. BENJAMIN et al.

DILLARD, Judge.

After Betty and Kerron Benjamin defaulted on a retail-installment contract,

Chrysler Financial Services Americas, LLC (“Chrysler FSA”) sued them to recover

the deficiency balance and later filed a motion for default judgment based on its belief

that they failed to file an answer. But after noting that the Benjamins, acting pro se,

had indeed filed an answer, the trial court dismissed Chrysler FSA’s case for failure

to prosecute and awarded the Benjamins attorney fees pursuant to OCGA § 9-15-14.

Chrysler FSA now appeals, arguing that the trial court abused its discretion. For the

reasons set forth infra, we affirm in part, reverse in part, vacate in part, and remand

the case for further proceedings consistent with this opinion. The record shows that in 2005, Kerron Benjamin and Betty Benjamin (Kerron’s

mother) entered into a retail-installment contract for the purchase of a Dodge pickup

truck with a local automobile dealership, which then sold the contract to Chrysler

FSA. Approximately three years later, the Benjamins took the truck back to the

dealership for repairs, which they believed were covered by the vehicle’s warranty.

But according to the Benjamins, after removing the truck’s engine, the dealership

informed them that the required repairs were not covered by the warranty. At this

point, believing that they should not be required to make payments on a vehicle they

could not drive, the Benjamins stopped making payments on the contract.

Shortly thereafter, Chrysler FSA repossessed the vehicle and resold it. The

resale amount, however, was less than the balance due on the Benjamins’ retail-

installment contract. Consequently, on February 22, 2010, Chrysler FSA filed a

lawsuit against the Benjamins, seeking to recover the deficiency balance on the

contract. Nine months later, Chrysler FSA voluntarily dismissed the action but then

re-filed it on February 22, 2011.

On March 22, 2011, the Benjamins filed an answer. But because Chrysler FSA

apparently never received a service copy of the answer, it believed the matter to be

in default. Nevertheless, the record does not indicate that any additional action was

2 taken until February 24, 2012 (almost one year later), at which point Chrysler FSA

successfully sought a continuance to prepare a motion for default judgment. Seven

more months passed, and on September 25, 2012, Chrysler FSA sought another

continuance, averring that such a continuance was necessary in order to complete an

affidavit supporting its soon-to-be-filed motion for default judgment. The trial court

granted the second continuance; however, Chrysler FSA did not file its motion for

default judgment until January 28, 2013.

On March 22, 2013, rather than ruling on the motion for default judgment, the

trial court dismissed Chrysler FSA’s complaint with prejudice for failure to prosecute

the case, noting that the case had lingered for over three years and that Chrysler FSA

had not appeared at four separate calendar calls. In addition, the trial court awarded

attorney fees to the Benjamins pursuant to OCGA § 9-15-14. This appeal follows.

At the outset, we note that a trial court’s order of dismissal for failure to

prosecute is discretionary and “is subject to appellate review for abuse of discretion.”1

And we will not substitute our judgment for the trial court’s judgment when “there

1 McKnight v. Wyrick, 247 Ga. App. 584, 585-586 (544 SE2d 507) (2001); accord Floyd v. Logisticare, Inc., 255 Ga. App. 702, 702 (1) (566 SE2d 423) (2002).

3 is no obvious abuse of discretion.”2 With these guiding principles in mind, we turn

now to Chrysler FSA’s claims of error.

1. Chrysler FSA contends that the trial court abused its discretion in dismissing

its complaint with prejudice for failure to prosecute its case, arguing that this sanction

was too severe. We do not agree that the court abused its discretion in dismissing the

case based on Chrysler FSA’s failure to prosecute, and thus, we affirm the court’s

judgment in that regard. That said, we do agree that the court erred in dismissing the

case with prejudice, and thus, we vacate that aspect of the court’s judgment and

remand with the direction noted infra.

Here, in its dismissal order, the trial court noted that the case had lingered for

approximately three years, that Chrysler FSA conducted no discovery during that

time, and that Chrysler FSA failed to attend at least four calendar calls. The court,

therefore, dismissed the case for failure to prosecute pursuant to OCGA § 9-11-41

(b).3 Chrysler FSA does not dispute that it failed to attend the various calendar calls

but, rather, argues that it did not think it was necessary to do so in light of its belief

2 McKnight, 247 Ga. App. at 586. 3 See OCGA § 9-11-41 (b) (“For failure of the plaintiff to prosecute or to comply with this chapter or any order of court, a defendant may move for dismissal of an action or of any claim against him. . . .”).

4 that the Benjamins were in default by failing to file an answer. This mistaken belief,

however, did not preclude an involuntary dismissal by the trial court. Indeed, it is a

fundamental principle of Georgia law that “counsel has a duty to keep himself

informed as to the progress of the cases he handles in a particular court, so that he

may take whatever actions may be necessary to protect the interests of his clients.”4

Consequently, Chrysler FSA’s reason for not attending the calendar calls is not at all

persuasive. Furthermore, “our prior case law in this area has shown extraordinary

deference to trial courts that have chosen to dismiss a civil action as a result of a

party’s failure to appear at a proceeding, calendar call, or the like.”5 Accordingly, the

trial court did not abuse its discretion in dismissing Chrysler FSA’s case.

4 Atlanta Bus. Video, LLC v. FanTrace, LLC, ___ Ga. App. ___, Slip op. at 6-7 (Case No. A13A1287; decided Nov. 7, 2013) (punctuation omitted); accord Hipple v. Simpson Paper Co., 234 Ga. App. 516, 517 (1) (507 SE2d 156) (1998). 5 Atlanta Bus. Video, LLC, Slip op. at 7; see Ector v. Unison Ins. Co., 228 Ga. App. 520, 521 (3) (492 SE2d 287) (1997) (affirming dismissal of plaintiff’s suit without prejudice “for failure to appear at the calendar call,” even though “the circumstances of this case understandably gave rise to some confusion” because ultimately “it was plaintiff’s responsibility to appear at the call or contact the court to clarify the status of the case in the absence of a continuation order”); see also Kraft, Inc. v. Abad, 262 Ga. 336, 336 (417 SE2d 317) (1992) (“OCGA § 9-11-41

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