Parish v. Peters

1 Cal. App. 4th 202, 1 Cal. Rptr. 2d 836, 91 Daily Journal DAR 14432, 1991 Cal. App. LEXIS 1340
CourtCalifornia Court of Appeal
DecidedNovember 22, 1991
DocketC008373
StatusPublished
Cited by20 cases

This text of 1 Cal. App. 4th 202 (Parish v. Peters) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Parish v. Peters, 1 Cal. App. 4th 202, 1 Cal. Rptr. 2d 836, 91 Daily Journal DAR 14432, 1991 Cal. App. LEXIS 1340 (Cal. Ct. App. 1991).

Opinion

*205 Opinion

SPARKS, Acting P. J.

In this case we confront a conundrum created by the interplay of various provisions of the Code of Civil Procedure governing the contents of complaints, the service of process, and the methods of obtaining a default judgment. Under the express statutory scheme, there is no provision for a defaulting defendant in a personal injury action who had been served by publication to be subsequently served with a statement of the damages sought by the plaintiff. The trial court found this lack of express statutory directive for such a statement to be determinative and consequently ruled that failure to serve a statement of damages did not entitle the defendant to relief from default.

In the published portion of this case, we hold that the proper service of a statement of damages or its equivalent, although not expressly required by statute under these circumstances, is compelled by due process. 1 In the absence of the proper service of such a constitutionally required notice, the court lacks jurisdiction to enter a default judgment. We further conclude that a prayer in the complaint for “compensatory damages according to proof” fails to give the requisite notice and hence cannot act as a substitute for a separate notice of damages. Accordingly, the judgment must be reversed.

Background

For purposes of the published portion of this opinion, our factual focus is narrow. In May 1987, plaintiffs Doris and Harold Parish, Jr., filed their form complaint in the superior court for personal injury, property damage, and loss of consortium allegedly resulting from a motor vehicle accident occurring 364 days earlier. The plaintiffs prayed for compensatory damages “according to proof.” Almost two years later, in February 1989, the plaintiffs filed an ex parte application for an order permitting service of process by publication. (Code Civ. Proc., § 415.50 [subsequent undesignated section references are to this code].) 2 The court issued the order, and the summons appeared in The Daily Recorder, a newspaper of general circulation for Sacramento County, on four consecutive Fridays in March 1989.

*206 On August 21, 1989, the plaintiffs filed a request for a court judgment. 3 (§ 585, subd. (c).) Under the heading “Statement of damages ([§] 425.11),” tiie plaintiffs claimed $1,790 in special damages and $40,000 in general damages. They also sought $198 in costs. Ten days later, the plaintiffs filed an application for a default judgment, set for September 7. (§ 587.) The application once again sought damages in the sum of $41,790, together with costs of $198. Attached to this application was a proof of service by mail on the defendant at an address in Rancho Cordova, California. Following a hearing at which plaintiff Doris Parish testified, the court entered a default judgment on October 17, 1989, in the amount claimed in the application.

Although the particular vehicle by which the defendant sought relief is ultimately irrelevant, we note the defendant initially moved in January 1990 to quash the summons for failure to publish it in a newspaper most likely to give him actual notice (§ 418.10), to set aside the default for lack of actual notice without inexcusable neglect or avoidance of service (§ 473.5), and to set aside the default under the general relief statute (§ 473). The motion appended his proposed answer. The court denied the motions. The defendant next moved to set aside the judgment (invoking § 473) on the specific ground the plaintiffs did not serve the section 425.11 statement of damages on the defendant more than 30 days before the request for a default judgment, at which point they sent one to an incorrect address. He again appended his proposed answer. The court once more denied the motion: “[Defense counsel], you’re asking the Court to invalidate the default judgment on the ground that no statement of damages was served. The law does not require it.”

The defendant now appeals from the default judgment and the two orders entered after judgment denying relief from judgment. He claims the judgment is void either for failure to serve a statement of damages or because service by publication was improper. He further claims the trial court abused its discretion in failing to set aside the default under section 473.5 because he did not attempt to evade service • and was not guilty of inexcusable neglect. In the published portion of this opinion, we limit our consideration to his claim that the judgment was invalid because he was not served with a statement of damages pursuant to section 425.11.

*207 Discussion

I *

II

Defendant contends that the default judgment entered against him is void because plaintiffs failed to serve him with a statement of damages as required by section 425.11. Plaintiffs counter that such a statement is not required when service has been made by publication.

A.

The starting point for our analysis is section 580, which states quite simply, “The relief granted to [a] plaintiff, if there be no answer, cannot exceed that which [is] demanded in [the] complaint . . . .” As the Supreme Court held without qualification in Greenup v. Rodman (1986) 42 Cal.3d 822 [231 Cal.Rptr. 220, 726 P.2d 1295], “in all default judgments the demand sets a ceiling on recovery.” (Id. at p. 824.) In its overview of section 580, the high court stated the statute should be “strictly construed” so that any default judgment in excess of the amount specifically demanded is void as extra-jurisdictional. (Id. at p. 826.) “The notice requirement of section 580 was designed to insure fundamental fairness. Surely this would be undermined if the door were opened to speculation, no matter how reasonable it might appear in a particular case that a prayer for damages according to proof provided adequate notice of a defaulting defendant’s potential liability.” (Ibid, [internal quotation marks deleted].)

Section 580 constitutes a statutory expression of the mandates of due process, which require “formal notice of potential liability.” (42 Cal.3d at p. 826; accord, Petty v. Manpower, Inc. (1979) 94 Cal.App.3d 794, 798 [156 Cal.Rptr. 622] [California has codified constitutional protection of notice].) Those mandates also require that the form of substituted service be “reasonably calculated to give [the defendant] actual notice of the proceedings and an opportunity to be heard. If it is, the traditional notions of fair play and substantial justice [citation] implicit in due process are satisfied.” (Milliken v. Meyer (1940) 311 U.S. 457, 463 [85 L.Ed. 278, 283„ 61 S.Ct. 339, 132 A.L.R.

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Cite This Page — Counsel Stack

Bluebook (online)
1 Cal. App. 4th 202, 1 Cal. Rptr. 2d 836, 91 Daily Journal DAR 14432, 1991 Cal. App. LEXIS 1340, Counsel Stack Legal Research, https://law.counselstack.com/opinion/parish-v-peters-calctapp-1991.