Pinkham v. Plate

Summary

The Idaho Supreme Court affirmed the denial of the defendants’ motion to set aside the entry of default because the defendants failed to timely file a notice of appearance or self-representation after their attorney withdrew and did not establish good cause. The court nevertheless vacated the default judgment because the complaint pleaded no specific damages and the record contained no proof or adequate explanation supporting the nearly $650,000 award. The case was remanded for determination of damages based on appropriate proof, and attorney fees were denied to both sides.