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Schwab v. Rondel Homes, Inc.

California Supreme Court

808 P.2d 226 (1991)

Relevant factsFree

Allen and Schwab (plaintiffs) sued Rondel Homes (defendant) for housing discrimination after Rondel refused to rent to them because of Allen's signal dog, despite being told of Allen's need for the dog and given materials on the relevant legal rights. Their complaint sought emotional distress damages, further damages to be proved at trial, statutory treble damages of at least $250, attorneys' fees, and $500,000 in punitive damages; Rondel never responded, and the trial court entered a default judgment, later awarding $50,000 general damages and $100,000 punitive damages per plaintiff plus fees. Rondel moved to set aside the default, and the trial court found Allen and Schwab never served a statement of the specific damages sought and vacated the judgment; the Court of Appeal reversed and reinstated most of the award, though it capped general damages at $25,000 per plaintiff, and the California Supreme Court granted review.

IssueFree

Whether plaintiffs must provide defendants with actual notice of the specific amount of damages sought before a default judgment may be granted.

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