Candace Vanasse, Petitioner v. William J. Ramsay, M.d. and Teton Eye Clinic, Respondents

Summary

The Wyoming Supreme Court held that Rule 55(b) does not require a formal written application for a default judgment and that the district court abused its discretion by setting aside both the default and default judgment. The defendants failed to establish excusable neglect, surprise, or another Rule 60(b) basis, and their culpable failure to respond defeated good cause under Rule 55(c). Justice Urbigkit specially concurred, agreeing with the result but rejecting reliance on an earlier precedent and emphasizing the absence of reasoned justification for relief.