Court of Civil Appeals Reverses Trial Court’s Setting Aside of a Domesticated Default Judgment Pursuant to Rule 60(b)

In Cambria v. Worldwide Custom Materials, Inc., No. 2070855, released by the Alabama Court of Civil Appeals, the court reversed the trial court’s order setting aside a domesticated default judgment pursuant to Rule 60(b). 

Cambria sued Worldwide Custom Materials, Bramlett, and Groves in Minnesota seeking to recover a debt he was allegedly owed. Neither Worldwide, Bramlett, or Groves answered, so the Minnesota court entered a default judgment against them. 

Pursuant to the Uniform Enforcement of Foreign Judgments Act (“the UEFJA”), codified at §6-9-230 of the Alabama Code, Cambria filed a Notice of Filing Judgment in the trial court. In response, Worldwide, Bramlett, and Groves filed a Rule 60(b)(4) motion seeking to set aside the domesticated Minnesota judgment as void on the ground that the Minnesota court lacked personal jurisdiction due to improper service. None of them, however, provided any evidence in support of their contentions. The trial court entered an order setting aside the Minnesota judgment without stating its rationale for doing so. 

The Court of Civil Appeals stated the standard of review:

The standard of review on appeal from an order granting relief under Rule 60 (b)(4)

Ala. R. Civ. P. (“the judgment is void”), is not whether the trial court has exceeded its  discretion.   When the decision to grant or to deny relief turns on the validity of the             judgment, discretion has no field of operation. If the judgment is void, it is to be set             aside; if is valid, it must stand….A judgment is void only if the court which rendered it    lacked jurisdiction of the subject matter, or of the parties, or if it acted in a manner           inconsistent with due process.  

(internal citations omitted).

The court further noted that “the judgment of the court of another state having jurisdiction of the subject matter and persons is entitled to full faith and credit in Alabama courts. The authentication and filing of a sister state’s judgment with a circuit court of this state in accordance with the UEFJA creates a rebuttable presumption that the court rendering that judgment had jurisdiction to do so and shifts to the party challenging that judgment the burden of producing evidence to rebut the presumption. 

Here, a rebuttable presumption arose when Cambria authenticated and filed the Minnesota judgment in accordance with the UEJFA. Although Worldwide, Groves, and Bramlett made unsworn allegations that they had not been served with process in the Minnesota court, they failed to produce any evidence to prove those unsworn allegations or to otherwise rebut the presumption. 

Therefore, the trial court’s order setting aside the Minnesota judgment was reversed.