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Abercrombie v. Richards

Citations: 248 Ark. 1322; 455 S.W.2d 887; 1970 Ark. LEXIS 1367Docket: 5-5307

Court: Supreme Court of Arkansas; June 29, 1970; Arkansas; State Supreme Court

Narrative Opinion Summary

This case concerns an appellant’s attempt to vacate three default judgments entered against him following consolidated actions for money owed. After responding to the original suits with a general denial and counterclaim, the appellant, through counsel, sought a trial continuance on the grounds of illness, supported only by informal statements lacking medical verification. The trial court warned that absent competent medical evidence, default judgments would issue. When such evidence was not provided, default judgments were entered. Subsequent motions to vacate on grounds of illness and lack of notice, including a petition filed after the term of judgment, were denied due to the absence of excusable negligence, lack of verified medical evidence, and failure to allege a specific meritorious defense. On appeal, the court affirmed these rulings, reiterating that post-term relief from a default judgment requires a detailed and substantiated claim of a meritorious defense. The appellant’s generalized assertions were found insufficient, and the dismissal of the petition to vacate was upheld. The decision reinforces strict procedural and evidentiary requirements for setting aside default judgments after the expiration of the term.

Legal Issues Addressed

Insufficiency of General Allegations—Lack of Specificity in Meritorious Defense

Application: The court held that the appellant’s assertion of a meritorious defense was inadequate because it lacked specific details and did not substantiate a valid defense.

Reasoning: The court found that the appellant's claim of a "meritorious defense" lacked specific details and did not substantiate a valid defense.

Petition to Vacate Default Judgment After the Term—Requirement of Meritorious Defense

Application: The court reaffirmed that after the expiration of the term, a party seeking to vacate a default judgment must allege and demonstrate a meritorious defense, which the appellant failed to do.

Reasoning: The court affirmed the dismissal of the appellant's petition, emphasizing that to successfully vacate a default judgment after the term, a meritorious defense must be alleged and demonstrated.

Relief from Default Judgments—Necessity of Excusable Negligence

Application: The court dismissed the motion to vacate the judgments because the appellant failed to establish excusable negligence or to provide verified medical evidence supporting his absence.

Reasoning: The court dismissed this motion, citing a lack of excusable negligence and absence of verified medical evidence.

Vacation of Default Judgments—Requirement of Verified Medical Evidence for Continuance

Application: The court required the appellant to provide competent, verified medical evidence to justify a continuance due to illness before trial, and absence of such evidence led to the entry of default judgments.

Reasoning: The court indicated it would enter default judgments unless competent medical evidence was provided to demonstrate the appellant's inability to appear.