Chen v. Mah
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In this compensation dispute based on an oral agreement between Plaintiff and Defendants the Supreme Court affirmed the intermediate court of appeals' (ICA) judgment on appeal affirming the circuit court's final judgment, holding that the circuit court did not abuse its discretion in denying Defendants' Haw. R. Civ. P. 55(c) motion to set aside entry of default and did not err in its other rulings.
The circuit court entered default and subsequent default judgment as to certain claims against defendants. After a bench trial regarding damages on the remaining claims the circuit court entered judgment in favor of Plaintiff and against Defendants. The ICA affirmed. The Supreme Court affirmed, holding (1) the circuit court did not abuse its discretion in denying Defendants' motion to set aside entry of default; and (2) prospectively, a Rule 55(c) motion to set aside entry of default is to be evaluated based only on whether there has been a showing of "good cause."
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