Gillman v. Gillman, 2021 UT 33 (July 22, 2021)

On interlocutory appeal from the district court’s order setting aside a default certificate under Utah R. Civ. 55(c), the supreme court rejected the argument that a showing of “good cause” under Rule 55(c) demands some reason for the default beyond the defaulting party’s own inaction. Emphasizing instead that “[v] acatur of a default is an equitable remedy,” the court held that a showing of “good cause” under “Rule 55(c) requires only that a movant make a showing that is sufficient to persuade the district court that the default should be set aside.”