No. Once the court makes a final ruling because Franklin didn't show up to defend itself, it's too late for Franklin to argue about whether it was at fault. The court said there's a specific, early window of time to challenge being found in 'default,' but Franklin missed it. By ignoring the lawsuit, Franklin essentially admitted it was liable. After the final judgment, the only thing it could argue about was the amount of money it was ordered to pay, not whether it should have to pay at all.

No, the court did not make a mistake. When a company doesn't respond, it's like they're admitting they did something wrong. The court can only change the punishment later, not the decision that the company is responsible. Franklin didn't try to undo the automatic win earlier, so they can't argue about being responsible later. The court was right to say no to Franklin's request because the rules only let the court change the punishment after an automatic win, not the blame.

No. A defendant may not challenge the legal viability of the plaintiff's claims in a post-judgment motion after a final default judgment has been entered. The court held that a default judgment is considered a final admission of liability. The proper time for a defendant to challenge liability is through a motion to vacate the initial order of default, as provided by Maryland Rule 2-613(d). Once a final default judgment is entered, Rule 2-613(g) expressly limits the court’s revisory power under Rules 2-534 and 2-535 to the 'relief granted' (i.e., the amount of damages), not the underlying liability determination. Because Franklin failed to move to vacate the order of default, it lost its opportunity to contest liability and could not resurrect those arguments in a post-judgment motion.

Yes, the circuit court did not err. A default judgment is considered an admission of liability, and the court's revisory power is limited to the relief granted, not liability determinations. Because Franklin did not move to vacate the order of default, it could not later revisit the issue of liability through a motion to alter or amend the judgment under Rule 2-534 or 2-535(a). The circuit court properly denied Franklin's post-judgment motion because Rule 2-613(g) limits the court's ability to revise a default judgment to the relief granted, not liability.

Franklin Credit Management Corp. v. Nefflen

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