Bailey v. Algonquin Gas Transmission Co.

FLANDERS, Justice,

concurring.

In assessing the relative prejudice to the parties caused by the entry of the default judgment and the motion justice’s refusal to vacate same, there is one other equitable factor that, in my judgment, supports the motion justice’s discretionary ruling. In this case, the prejudice to Maguire caused by its own lawyer’s misconduct still could be alleviated if it is able to obtain contribution from one or more of the other defendants for any amount of the default judgment that it pays to the plaintiffs in excess of its pro-rata share of the plaintiffs’ damages. See G.L.1956 § 10-6-4 (“[a] joint tortfeasor is not entitled to a final money judgment for contribution until he or she has by payment discharged the common liability or has paid more than *489his or her pro rata share of the final money judgment.”).

In Calise v. Hidden Valley Condominium Association, Inc., 773 A.2d 834 (R.I. 2001), this Court held that a defaulted defendant could not seek to reduce the amount of its liability to the plaintiffs based upon the alleged disproportionate fault of the other joint tortfeasors who had already settled with the plaintiffs before the Super. R. Civ. P. 55(b)(2) hearing on damages. But Calise did not address whether a defaulted defendant — after it has discharged its liability to the plaintiffs by paying the amount of a default judgment in excess of its pro rata share of the plaintiffs’ damages — could still obtain contribution from the other alleged joint tort-feasors. See § 10-6-8 (providing that joint tortfeasors are not released from liability to make contribution to another joint tortfeasor “unless the release is given before the right of the other tortfeasor to secure a money judgment for contribution has accrued”).

Here, unlike Calise, the other alleged joint tortfeasors neither have settled the claims against them nor obtained a joint tortfeasor’s release from the plaintiffs before the default judgment entered against the defendant (Maguire) who may be entitled to contribution. Thus, given that the plaintiffs’ claims against the other defendants are still pending, it may yet be possible in this case for Maguire to pay the default judgment and then to obtain contribution from one or more of the other defendants, either by filing cross-claims against them or by filing an independent action seeking such relief.