Darlette Ewing v. Lea Schmalz

2024 Ark. App. 127, 686 S.W.3d 25
CourtCourt of Appeals of Arkansas
DecidedFebruary 21, 2024
StatusPublished
Cited by4 cases

This text of 2024 Ark. App. 127 (Darlette Ewing v. Lea Schmalz) is published on Counsel Stack Legal Research, covering Court of Appeals of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Darlette Ewing v. Lea Schmalz, 2024 Ark. App. 127, 686 S.W.3d 25 (Ark. Ct. App. 2024).

Opinion

Cite as 2024 Ark. App. 127 ARKANSAS COURT OF APPEALS DIVISION III No. CV-23-109

DARLETTE EWING Opinion Delivered February 21, 2024

APPELLANT APPEAL FROM THE LOGAN COUNTY CIRCUIT COURT, V. NORTHERN DISTRICT [NO. 42PCV-21-95] LEA SCHMALZ APPELLEE HONORABLE TERRY SULLIVAN, JUDGE

AFFIRMED IN PART; DISMISSED IN PART

CINDY GRACE THYER, Judge

Darlette Ewing appeals the Logan County Circuit Court’s entry of a default judgment

against her and its award of attorney’s fees. Ewing first claims that a default judgment should

not have been entered because she timely “appeared” and sought to contest the action. She

also claims that the equitable doctrines of waiver and laches preclude Schmalz’s right to a

default judgment. Next, she argues that the court erred in denying her motion to set aside

the default judgment because the default here was largely technical, Schmalz was not

prejudiced by any delay, and there is a meritorious defense to the action. Finally, she argues

that the trial court erred in granting attorney’s fees, claiming fees are not authorized in the

type of case presented here. Because Ewing’s arguments regarding the entry of default

judgment and the award of attorney’s fees have no merit, we affirm. However, because her arguments regarding the court’s denial of her motion to set aside are premature, we dismiss

without prejudice that portion of her appeal.

I. Factual and Procedural History

The underlying dispute in this case involves the ownership and possession of a 1979

Chevrolet Corvette. In July 2017, Frank Schluterman (Ewing’s father) and Schmalz

purchased the Corvette and titled it in both their names.1 When Schluterman died in

November 2020, Schmalz had a new title issued reflecting that she was the sole owner of the

vehicle. Schmalz, however, was not in possession of the vehicle at that time; Ewing was.

Schmalz requested that Ewing return the car to her on multiple occasions, but Ewing refused

to do so.

On October 4, 2021, Schmalz, claiming to be the rightful owner of the car, filed suit

against Ewing for replevin, conversion of personal property, unjust enrichment, and trespass

to chattel. She sought return of the vehicle, damages, and attorney’s fees. The court entered

an order for delivery and set a hearing for December 1. Ewing was personally served with the

summons, complaint, and accompanying documentation on November 30 and again at the

hearing on December 1.

At the December 1 hearing, Ewing appeared and asked for additional time to hire an

attorney. Schmalz did not object. The court then entered an order instructing Ewing to

review the complaint and summons and “direct her actions accordingly.” The court then

1 Specifically, the car was titled: “Schluterman, Frank Edward or Schmalz, Lea.”

2 continued the matter “until [Ewing] files an Answer in accordance with the Arkansas Rules

of Civil Procedure, [Ewing] hires an attorney, and/or the parties contact the Court and

request a hearing.” The court noted that the Corvette (and its various parts and contents)

was in the possession of Schmalz’s mechanic and was to remain there pending further court

order.

Ewing hired an attorney and eventually answered the complaint on January 11, 2022—

forty-two days from the November 30 service date and forty-one days from the December 1

service date. On April 14, 2022, Schmalz moved for default judgment, arguing that Ewing

had failed to timely file an answer and requesting, in part, the return of the vehicle, an award

of damages, and an award of attorney’s fees.

When Ewing failed to file a timely response to the motion, Schmalz’s counsel

contacted the court by letter dated May 6, 2022, and requested that the court enter her

proposed order granting a default judgment or, in the alternative, set the matter for a

hearing. Three days later, Ewing filed her response arguing that Schmalz lacked the authority

to obtain a “retroactive” default judgment. She further argued that the court had granted

her permission to file a late answer; thus, a default judgment was not appropriate.

Schmalz filed a reply, denying that the court had granted Ewing permission to file a

late answer. To the contrary, she argued that the court had instructed Ewing to “read the

Summons and direct her actions accordingly” and had continued the matter until she filed

an answer “in accordance with the Arkansas Rules of Civil Procedure,” hired an attorney, or

the parties requested a hearing. She further denied that she was attempting a “retroactive”

3 default or that she had waived her entitlement to a default judgment by waiting until April

to file the motion. Finally, Schmalz asked that Ewing’s response be struck as untimely.

On October 19, 2022, the parties appeared for trial. However, before hearing

testimony or taking any evidence on the merits of the action, the court entertained counsel’s

arguments on Schmalz’s motion for default judgment.

Schmalz argued that Ewing had appeared at the hearing on December 1, confirmed

that she had been served, and was instructed to review the documents, including the

summons, and to direct her actions accordingly. Schmalz insisted that the court’s subsequent

order reflected that; yet Ewing’s answer was filed more than thirty days after the date of

service.

Ewing responded that default judgments are not favored and that the standard for

granting a default is whether the party with the delayed response was ready to defend the

litigation. Ewing asserted that she was not only ready to defend, but she had been defending

against the action for more than a year. She argued that Schmalz lost whatever opportunity

she had to seek such a drastic remedy by her delay in the filing of her motion and by her

failure to seek relief at a hearing sooner than the day of trial. Ewing contended that she was

prejudiced by this delay because she and her witnesses expended time and money preparing

for trial. Finally, she argued that the court had the authority to grant leave for the filing of a

late response, and the December 2021 continuance order appeared to toll the time in which

to respond until after she obtained counsel; thus, her answer was not untimely. Notably, the

record is silent as to when, exactly, Ewing retained counsel.

4 After hearing the arguments of counsel, the circuit court found that Ewing’s answer

was untimely. The court first noted that its December 2021 continuance order instructed

Ewing to review the complaint and summons and to direct her actions accordingly. It further

stated that the matter was continued until Ewing had filed an answer in accordance with the

Arkansas Rules of Civil Procedure, hired an attorney, or the parties contacted the court

requesting a hearing. The court found that nothing in that order granted Ewing the authority

to file a late answer. As a result, the court held that Ewing was in default as to liability, and

the court proceeded to the damages portion of the trial.

As part of the trial on damages, Schmalz testified as to the amount of attorney’s fees

and costs she incurred in an effort to recover the Corvette. Ewing argued that attorney’s fees

and costs were not recoverable, and to the extent they might be deemed recoverable, they

were limited to the filing of the complaint and motion for default judgment. Schmalz argued

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Cite This Page — Counsel Stack

Bluebook (online)
2024 Ark. App. 127, 686 S.W.3d 25, Counsel Stack Legal Research, https://law.counselstack.com/opinion/darlette-ewing-v-lea-schmalz-arkctapp-2024.