Much v. Doe

493 P.3d 38, 311 Or. App. 652
CourtCourt of Appeals of Oregon
DecidedMay 26, 2021
DocketA168009
StatusPublished
Cited by4 cases

This text of 493 P.3d 38 (Much v. Doe) is published on Counsel Stack Legal Research, covering Court of Appeals of Oregon primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Much v. Doe, 493 P.3d 38, 311 Or. App. 652 (Or. Ct. App. 2021).

Opinion

Argued and submitted June 15, 2020, affirmed May 26, 2021

Linda MUCH, Plaintiff-Appellant, v. Jane DOE, an unknown party, Defendant, and FRED MEYER STORES, INC., a foreign corporation, Defendant-Respondent. Yamhill County Circuit Court 18CV03056; A168009 493 P3d 38

Plaintiff appeals an order of the trial court granting defendant’s motion for relief from a default judgment on the ground of mistake, inadvertence, or excus- able neglect. ORCP 71 B(1)(a). Plaintiff contends that the court erred in consider- ing defendant’s declarations, submitted in support of the motion, because the dec- larations did not include the phrase “subject to penalty for perjury,” as required by ORCP 1 E. Plaintiff asserts that, without the declarations, defendant did not establish a ground for relief from the judgment. Held: Plaintiff did not raise her objection to the declarations by written motion as required by ORCP 14; thus, plaintiff’s challenge to the trial court’s consideration of the declarations either is not preserved or does not constitute error. The record supports the court’s finding that defendant’s default was the result of mistake, inadvertence, or excusable neglect, and the Court of Appeals concluded that the court did not abuse its dis- cretion in granting defendant’s motion to set aside the judgment. Affirmed.

Ronald W. Stone, Judge. Joshua B. Lay-Perez argued the cause and filed the briefs for appellant. Megan J. Crowhurst argued the cause for respondent. Also on the brief were Francis T. Barnwell and Kalia J. Walker. Before Armstrong, Presiding Judge, and Tookey, Judge, and Aoyagi, Judge. Cite as 311 Or App 652 (2021) 653

ARMSTRONG, P. J. Affirmed. Aoyagi, J., concurring. Tookey, J., dissenting. 654 Much v. Doe

ARMSTRONG, P. J. Plaintiff brought a wage claim against defendant Fred Meyer and obtained a default judgment after defen- dant failed to appear. Plaintiff appeals an order of the trial court granting defendant’s motion for relief from the default judgment on the ground of mistake, inadvertence, or excus- able neglect. ORCP 71 B(1)(a).1 For the reasons explained below, we reject plaintiff’s assignments of error and affirm the trial court. In support of defendant’s contention that its failure to appear was the result of mistake, inadvertence, or excus- able neglect, defendant offered the declarations of members of its legal staff explaining that, in the lengthy process of routing notice of plaintiff’s action to the correct legal depart- ment, defendant’s staff neglected to forward a copy of the summons and complaint. The trial court held a hearing on the motion and granted it, concluding: “Now, let’s get to the heart of the thing and that is whether there is evidence sufficient to meet the premise of the law to set aside the default based on mistake, inadvertence or excusable neglect. Clearly that’s exactly what happened here.” Plaintiff’s first assignment on appeal asserts: “The trial court erred as a matter of law in considering declarations and attached exhibits that was [sic] not under penalty of perjury as required by ORCP 1 E,2 OEC 603, and ORS 153.080, in setting aside the order of default.”

1 ORCP 71 B(1) provides: “On motion and upon such terms as are just, the court may relieve a party or such party’s legal representative from a judgment for the follow- ing reasons: (a) mistake, inadvertence, surprise, or excusable neglect * * *. A motion for reasons (a), (b), and (c) shall be accompanied by a plead- ing or motion under Rule 21 A which contains an assertion of a claim or defense.” 2 ORCP 1 E provides: “A declaration made within the United States must be signed by the declarant and must include the following sentence in prominent letters immediately above the signature of the declarant: ‘I hereby declare that the above statement is true to the best of my knowledge and belief, and that I understand it is made for use as evidence in court and is subject to penalty for perjury.’ ” Cite as 311 Or App 652 (2021) 655

Defendant responds that the asserted claim of error is not preserved or properly before the court, and we agree. Preliminarily, we note that plaintiff’s assignment of error is not directed to any ruling of the court and therefore is not a proper assignment. ORAP 5.45(3) (“Each assignment of error shall identify precisely the legal, procedural, fac- tual, or other ruling that is being challenged.”). As we said in Village at North Pointe Condo. Assn. v. Bloedel Const., 278 Or App 354, 359, 374 P3d 978, adh’d to on recons, 281 Or App 322, 383 P3d 409 (2016), “[c]ompliance with ORAP 5.45 is not a matter of mere form; it is crucial to our ability to review trial court rulings for error and to determine whether the appellant’s claims of error were preserved.” A court’s con- sideration of declarations submitted with a motion brought under ORCP 71 B(1) is not a “ruling.” An appropriate assign- ment might have been that the court erred in denying at the ORCP 71 hearing an oral motion that plaintiff made to strike the declarations, which would have highlighted the fact that the court did not rule on plaintiff’s oral motion, explaining, perhaps, why plaintiff chose to assign error in the manner that she did. Contrary to the dissent’s assumption, plaintiff’s argument in support of her assignment of error—viz., that the court erred in admitting the declarations—is not an assignment of error. Assuming, however, that plaintiff’s briefing is sufficient to apprise us of the ruling being chal- lenged on appeal, we reject plaintiff’s assignment, either because it is not preserved or because it does not constitute error. In the trial court, plaintiff first mentioned the omission from the declarations of the “penalty for perjury” clause in a footnote on the thirteenth page of her sur-reply memorandum, without argument.3 Then, at the hearing

Defendant’s declarations did include a statement immediately above the declar- ant’s signature line, but it is missing the concluding clause, “and is subject to penalty for perjury”: “I hereby declare that the above statement is true to the best of my knowledge and belief and that I understand it is for use as evidence in court.” 3 Plaintiff’s objection, in its entirety, stated: “Plaintiff also objects to Defendant’s declarations for non-compliance with ORCP 1 E by failing to obtain declarations under penalty of perjury.” 656 Much v. Doe

on defendant’s motion to set aside the judgment, plaintiff made an oral motion to strike the declarations as “inadmis- sible and void for failing to be under penalty of perjury as required under ORCP 1 E,” again without argument. The trial court did not rule on plaintiff’s oral motion, nor was it required to do so. That is because the court did not have a proper motion before it. ORCP 14 provides: “An application for an order is a motion. Every motion, unless made during trial, shall be in writing, shall state with particularity the grounds therefor, and shall set forth the relief or order sought.” A motion, other than one made at trial, must be in writing. The footnote in plaintiff’s sur-reply memorandum was not a motion; and plaintiff’s motion made at the hearing, which was not a trial or a trial-like proceeding, was not in writ- ing. The written declarations submitted by defendant with its motion under ORCP 71 B(1)(a) were a part of the trial court’s record. Had plaintiff wished the court not to consider the written declarations, she should have filed a written motion to strike them on which the court would then have ruled. Had the court been presented with a proper motion, it could have directed defendant to correct the declarations to include the missing “penalty of perjury” clause or could at least have given defendant the opportunity to do that.

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Cite This Page — Counsel Stack

Bluebook (online)
493 P.3d 38, 311 Or. App. 652, Counsel Stack Legal Research, https://law.counselstack.com/opinion/much-v-doe-orctapp-2021.