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Appeals court weighs Rule 60(b) challenge tied to mental‑health evidence and default judgment
Summary
In DeGangi v. Quinn the panel examined whether the trial court abused its discretion in denying a Rule 60(b) motion to set aside a default judgment, focusing on alleged mental‑health impairment, meritorious defenses, derivative versus direct claims, and the proper standard of review.
The Appeals Court heard argument in a commercial dispute in which the appellant sought relief from a default judgment under Rule 60(b), arguing mental‑health issues and other factors made his default excusable and that the trial court failed to conduct the full Baruvi (Rule 60(b)) analysis. Appellee counsel urged affirmation, saying the trial court properly found the appellant was not legally incompetent and did not abuse its discretion.
Why it matters: The case concerns standards for vacating default judgments where mental…
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