Choice Hotels International, Inc. v. Grover
United States Court of Appeals for the Seventh Circuit
792 F.3d 753 (7th Cir. 2015)
After being sued by Choice Hotels (plaintiff), defendants including Grover failed to answer the complaint through successive attorneys Chawla and Johnson, neither of whom filed an answer or moved to vacate an entered default; the district court entered a default judgment for Choice Hotels, and the defendants later hired new counsel and moved to set aside that judgment based on their prior lawyers' inadequate representation, which the district court denied. The defendants appealed.
Whether a civil litigant may obtain relief from a default judgment based on his own attorneys' abandonment or inadequate representation, or whether his remedy instead lies exclusively in a malpractice claim against those attorneys.