ia v. Wozniak

2020 COA 10
CourtColorado Court of Appeals
DecidedJanuary 16, 2020
Docket18CA2098, Spiremed
StatusPublished
Cited by170 cases

This text of 2020 COA 10 (ia v. Wozniak) is published on Counsel Stack Legal Research, covering Colorado Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
ia v. Wozniak, 2020 COA 10 (Colo. Ct. App. 2020).

Opinion

The summaries of the Colorado Court of Appeals published opinions constitute no part of the opinion of the division but have been prepared by the division for the convenience of the reader. The summaries may not be cited or relied upon as they are not the official language of the division. Any discrepancy between the language in the summary and in the opinion should be resolved in favor of the language in the opinion.

SUMMARY January 16, 2020

2020COA10

No. 18CA2098, Spiremedia v. Wozniak — Civil Procedure — Default — District Court Practice Standards — Default Judgments

A division of the court of appeals considers whether, when a

district court denies a motion for default judgment for failure to

comply with C.R.C.P. 55 and 121, section 1–14, the court is

required to explain the basis for its denial. The division concludes

that Rule 121, section 1-14(2), requires the court to provide the

parties with a sufficient explanation to afford the moving party an

opportunity to identify and correct the deficiency, if it can.

The appellant filed two motions for default judgment, both of

which the district court denied for not complying with the

requirements listed in Rule 121, section 1-14. When it denied both

motions, the district court did not provide any explanation as to how the motions failed to satisfy section 1-14. Further, when the

court denied the second motion for default judgment, it also

dismissed the case for violation of the court’s delay reduction order.

After reviewing the second motion, the division concludes that

the motions were deficient. However, the division also concludes

that the district court was obligated to provide an explanation as to

how the motions failed to meet the requirements of Rule 121,

section 1-14. Under Rule 121, section 1-14(2), when a court

reviews a motion for default judgment, “[i]f further documentation,

proof or hearing is required, the court shall so notify the moving

party.” The division concludes that, under this rule, a court is

obligated to provide some explanation of how a motion for default

judgment is deficient such that a party can identify and attempt to

correct the deficiencies before the case is dismissed.

Because the district court didn’t adequately articulate its basis

for denying the motion for default judgment before dismissing the

case, the division reverses the judgment and remands the case for

further proceedings COLORADO COURT OF APPEALS 2020COA10

Court of Appeals No. 18CA2098 City and County of Denver District Court No. 18CV30504 Honorable Brian R. Whitney, Judge

Spiremedia Inc., d/b/a Spire Digital,

Plaintiff-Appellant,

v.

Timothy Richard Wozniak, a/k/a Timmy Wozniak,

Defendant-Appellee.

JUDGMENT REVERSED AND CASE REMANDED WITH DIRECTIONS

Division VI Opinion by JUDGE WELLING Terry and Berger, JJ., concur

Announced January 16, 2020

Bighorn Legal, Jonathan Hagn, Englewood, Colorado, for Plaintiff-Appellant

No Appearance for Defendant-Appellee ¶1 Spiremedia Inc. appeals the district court’s order denying its

motion for default judgment and dismissing the case for violation of

the district court’s delay reduction order (DRO).

¶2 This case raises an issue of first impression: What is a court

required to tell a party when it denies a motion for default judgment

pursuant to C.R.C.P. 55(b) and 121, section 1-14, and dismisses a

case for failure to comply with the rules? We conclude that a court

is required to identify the deficiencies in the motion that supports

its decision, particularly before taking the extraordinary step of

dismissing the case. Such an explanation provides a party an

opportunity to remedy the deficiencies in its motion. Because the

court here didn’t adequately articulate its basis for denying the

motion for default judgment before dismissing the case, we reverse

the judgment and remand the case for further proceedings.

I. Background

¶3 On February 8, 2018, Spiremedia filed its complaint against

Timothy Richard Wozniak for breach of contract and treble damages

for a dishonored check pursuant to section 13–21–109(2), C.R.S.

2019. Four days later, the district court issued a DRO, stating that

“application for entry of default under C.R.C.P. 55(a) must be filed

1 within 14 days after default has occurred. . . . Motions for entry of

default judgment must comply with C.R.C.P. 121, § 1-14.” The

DRO also warned (in bold and all capital letters) that “IF AN

ATTORNEY OR PRO SE PARTY FAILS TO COMPLY WITH THIS

ORDER, THE COURT MAY DISMISS THE CASE WITHOUT

PREJUDICE.”

¶4 On May 8, 2018, Spiremedia filed an affidavit of service

attesting that Wozniak was served outside of Colorado on May 6,

2018. (Under C.R.C.P. 12(a)(2), a defendant served outside of

Colorado has thirty-five days from the date of service to file an

answer or other initial response.) Thus, Wozniak had until June

10, 2018, to respond to the complaint. By June 15, 2018, however,

Wozniak had not filed any responsive pleadings or motion to

dismiss, so Spiremedia filed a motion for default judgment under

C.R.C.P. 55.

¶5 On July 11, 2018, the district court denied Spiremedia’s

motion for default judgment, stating only: “A motion for default

judgment must comport with the requirements of C.R.C.P. 121, § 1-

14. The Motion as filed does not do so, and is therefore presented

in an improper format. Accordingly, the Motion is DENIED.” The

2 court did not provide any explanation of those purported

deficiencies.

¶6 Two days later, Spiremedia, apparently uncertain was

deficienct about its first motion — but suspecting it may have been

a failure to include an affidavit stating Wozniak is not a minor,

incompetent, or a servicemember, see C.R.C.P. 121, § 1-14(1)(c) —

refiled the motion for default judgment, this time adding what it

referred to as an “affidavit equivalent” pursuant to the Uniform

Unsworn Declarations Act (UUDA), § 13–27–104(1), C.R.S. 2019,

averring compliance with C.R.C.P. 121, section 1-14(1)(c).

¶7 On September 10, 2018, the district court ruled on

Spiremedia’s second motion for default judgment as follows:

Plaintiff previously filed a motion for default judgment on June 15, 2018. That motion was denied for failure to comport with the requirements of C.R.C.P. 121 § 1-14. The current Motion is substantially identical to that motion, with the addition of a[n] unnotarized affidavit regarding Defendant’s servicemember status. Thus, as with the prior motion, this Motion does not comport with C.R.C.P. 121 § 1-14, and is therefore presented in an improper format. Accordingly, the Motion is DENIED. Furthermore, because Plaintiff has twice filed the Motion in an improper format, Plaintiff is in violation of this

3 Court’s Delay Reduction Order. The action is accordingly DISMISSED.

We will refer to this order as the Dismissal Order.

¶8 On September 19, 2018, Spiremedia filed a motion for

reconsideration of the Dismissal Order. It asserted that, after a

review of the requirements for a motion for default judgment listed

in C.R.C.P. 121, section 1-14, it was “unable to discern any

substantive defect in the papers already filed with the Court.” And

it told the court that, even if there was a defect, the court “has still

never notified [Spiremedia] as to what ‘further documentation,

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Bluebook (online)
2020 COA 10, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ia-v-wozniak-coloctapp-2020.