Reshard v. Stevenson (2022)

Citation: Reshard v. Stevenson (2022)
Parent Document: Reshard v. Stevenson (2022)
Jurisdiction: DC (municipal)
Effective Date: 2022-02-24
Original Source: https://www.courtlistener.com/opinion/6444934/reshard-v-stevenson/ ↗

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           Ms. Stevenson argues that Ms. Reshard’s challenge to the trial court’s
August 28 order denying relief under Rule 60(b) is moot because the motion to
vacate the default was subsumed by the entry of final judgment, which Ms. Reshard
did not timely appeal. Although at the time Ms. Reshard filed her February 12
motion the default had not become a default judgment, entry of a final judgment
does not moot a movant’s argument to set aside a default under Rule 55(c) but rather
makes the argument subject to the Rule 60(b) standards for setting aside a default
judgment. See Miranda, 754 A.2d at 280 n.4. The denial of a Rule 60(b) motion is
itself an appealable order, and Ms. Reshard timely appealed that order. So while we
cannot review the underlying judgment itself, the trial court’s denial of the Rule
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