North Dakota Supreme Court

Nygaard v. Volker

February 19, 20262026 ND 50

Summary

The North Dakota Supreme Court affirmed the default judgment entered after the district court struck Volker's answer and counterclaim as a discovery sanction, holding that Volker waived any arguments not raised in the district court and that Rule 60(b) is the exclusive avenue to vacate a default judgment. The court found no facial irregularities in the judgment and therefore declined to reverse.