David Steele v. Johnson Controls, Inc.

Summary

The Supreme Court of Missouri affirmed the denial of Johnson Controls’ motion to set aside a default judgment entered for David Steele. It held that Johnson Controls failed to establish good cause for its failure to respond, and that Rule 75.01 and the asserted punitive-damages errors could not provide an alternative basis for relief from the default judgment. The court concluded that alleged errors in the underlying default judgment, including the punitive-damages award, were not reviewable in this appeal.