Jeff Cornelius v. Ronald Browning

Summary

The opinion concurs in reversing the default judgment but disagrees with the majority's reasoning. It would require the trial court, when considering a motion to set aside a default judgment, to determine both whether Rule 60(b) relief is warranted and whether the three established default-judgment factors are satisfied. It would therefore remand for mandatory consideration of those factors, including whether the defendant's conduct contributed to the lack of service.