Peoples State Bank v. Hickey

Pekelis, J.

(dissenting) — I dissent. Default judgments are not favored under Washington law. Griggs v. Averbeck Realty, Inc., 92 Wn.2d 576, 581, 599 P.2d 1289 (1979). The majority acknowledges that the facts regarding Carol Hickey's lien were misrepresented. Nevertheless, it justifies upholding the default judgment by relying on Plattner v. *373Strick Corp., 102 F.R.D. 612 (N.D. Ill. 1984). In Plattner, the court held that Federal Rule of Civil Procedure 60(b)(3), which provides for setting aside judgments obtained through fraud, misrepresentation or other misconduct, requires the losing party to show that the fraudulent conduct prevented that party from fully and fairly presenting its case or defense. Plattner, 102 F.R.D. at 615-16.

Plattner is distinguishable, however. There, the fraud involved the plaintiff's allegedly false or "deliberately misleading" testimony at his deposition and at trial. Plattner, 102 F.R.D. at 614. The party challenging the judgment alleged that the plaintiff's testimony affected the fairness of the proceedings in that defense counsel developed his trial strategy based on erroneous assumptions about the facts. The Plattner court disagreed, concluding that even if the plaintiff had testified differently, "it would not 'have made a difference in the way [defendant's] counsel approached the case and prepared for trial."' Plattner, 102 F.R.D. at 617 (quoting Rock Island Bank & Trust Co. v. Ford Motor Co., 54 Mich. App. 278, 220 N.W.2d 799 (1974)).

In contrast, the misrepresentation in this case does not merely affect the "fairness" of the parties' relative positions at trial; rather, it affects the validity of the judgment itself. Peoples' counsel knowingly presented erroneous findings of fact which stated that Carol Hickey's lien was inferior or subordinate. These findings provided the legal basis for entry of the default judgment.4 Had the trial court known that Carol Hickey's lien was superior to Peoples' lien, it would have, no doubt, refused to enter judgment against Carol Hickey without conducting a hearing to determine whether the lien had been satisfied. CR 55(b)(2). Thus, the *374misrepresentation by Peoples' counsel subverted the integrity of the court itself:

[TJampering with the administration of justice . . . involves far more than an injury to a single litigant. It is a wrong against the institutions set up to protect and safeguard the public, institutions in which fraud cannot complacently be tolerated consistently with the good order of society.

Hazel-Atlas Glass Co. v. Hartford-Empire Co., 322 U.S. 238, 246, 88 L. Ed. 1250, 64 S. Ct. 997 (1944), overruled on other grounds in Standard Oil Co. v. United States, 429 U.S. 17, 18, 50 L. Ed. 2d 21, 97 S. Ct. 31 (1976).

The conduct of Peoples' counsel, unlike that of the plaintiff in Plattner, also violated CR 11. CR 11 imposes on each attorney the obligation to sign every pleading he or she submits to the court. An attorney's signature on a pleading:

constitutes a certificate by him that he has read the pleading . . .; that to the best of his knowledge, information, and belief, formed after reasonable inquiry it is well grounded in fact . . ., and that it is not interposed for any improper purpose

(Italics mine.) CR 11. Thus, CR 11 is designed to prevent abuse of the courts and preserve the trustworthiness of the judicial process.

Here, Peoples' attorney clearly violated CR 11 when he submitted findings to the court which misrepresented the facts. The assertion by Peoples' counsel that he did not know Carol Hickey's lien was superior is disingenuous: the attorney representing Peoples in this matter was the same attorney who had created Carol Hickey's lien when he represented her former husband in their dissolution. In any event, Peoples' attorney points to no factual basis to support his assertion that Carol Hickey's lien was inferior. Indeed, a title search would have revealed otherwise.

Nor is Peoples' new contention on appeal that its counsel reasonably believed the lien had been satisfied credible. Counsel could have easily ascertained whether the lien had been satisfied merely by contacting Peoples' mortgagor, Earl Hickey, or Carol Hickey, or by referring to the title *375report. This simple inquiry, required by CR 11, insures that attorneys, as officers of the court, honestly inform the tribunal of material facts which may affect the outcome of the controversy presented for judicial review. See Miller v. Badgley, 51 Wn. App. 285, 303, 753 P.2d 530 (1988) (attorneys may not avoid CR ll's requirement that they make a reasonable inquiry as to the factual basis for a motion "merely by claiming good faith conduct or personal ignorance of the groundless nature of a claim."),5 review denied, 111 Wn.2d 1007 (1988).

Finally, Fed. R. Civ. P. 60(b)(3), interpreted in Plattner, is not "the federal counterpart" of Washington's CR 60(b), as the majority contends. Under Fed. R. Civ. P. 60(b)(3), motions must be made within a reasonable time, and not more than 1 year after the judgment was entered, even in cases where the judgment was allegedly obtained by fraud, misrepresentation or misconduct. In contrast, Washington's CR 60(b) requires that motions which challenge a judgment on the basis of fraud, misrepresentation, or misconduct of an adverse party be made within a "reasonable time." It is only motions challenging judgments on grounds such as mistake, excusable neglect, inadvertence, irregularity or error in the proceedings, or newly discovered evidence which must be made within 1 year of the entry of judgment. CR 60(b).

Thus, Washington's rule, unlike Fed. R. Civ. P. 60(b)(3), implicitly acknowledges that the judicial system's interest in prompt litigation and finality must yield to the more important requirement that judgments be obtained without fraud or misrepresentation. Here, the panel agrees that Peoples obtained its default judgment by misrepresenting to the court that Carol Hickey's lien was inferior and subordinate to its own. Although Carol Hickey's negligence in *376failing to respond to Peoples' complaint is not conduct this court wishes to condone, our concern with the "salutary purposes served by finality of judgments" pales in comparison to our duty to uphold the integrity of judicial proceedings. "Surely it cannot be that preservation of the integrity of the judicial process must always wait upon the diligence of litigants." Hazel-Atlas, 322 U.S. at 246. The majority's decision, in penalizing an inattentive litigant, rewards a party who, with the assistance of counsel, has obtained a favorable judgment through misrepresentation. I dissent.

Review denied at 113 Wn.2d 1029 (1989).

In order to obtain a judgment of default, the moving party must present evidence to the court or commissioner which establishes its entitlement to the precise relief it seeks. CR 55(b). In contrast, a party may obtain an order of default without making any factual showing demonstrating its entitlement to the relief sought in the underlying complaint. The moving party need only establish proper service of the complaint and the motion for default, the absence of any response or appearance by the nonmoving party, and proper venue for the action. CR 55(a).

Arguably, counsel's conduct also violated RPC 3.3 which prohibits a lawyer from "knowingly" making a "false statement of material fact or law to a tribunal", and RPC 8.4 which prohibits attorneys from engaging "in conduct involving dishonesty, fraud, deceit or misrepresentation" and "in conduct that is prejudicial to the administration of justice". RPC 8.4(c), (d).