M.R. v. COUNTY OF ALAMEDA

Background

The County of Alameda moved under Rule 55(c) of the Federal Rules of Civil Procedure to set aside an entry of default. An entry of default is a court notation that a party failed to respond as required. The plaintiffs’ opposition was due September 4, 2026, but they filed neither an opposition nor the required statement of non-opposition.

Court’s Analysis

Rule 55(c) permits a court to set aside an entry of default for “good cause.” The court considered whether the County engaged in culpable conduct that caused the default, whether the County lacked a possible meritorious defense, and whether setting aside the default would prejudice the plaintiffs. The court also emphasized that default is a drastic remedy generally reserved for extreme circumstances and that cases should ordinarily be decided on their merits when possible.

The court found that the County’s failure to respond appeared to result from inadvertent calendaring mistakes, not bad faith or an effort to manipulate the legal process. It also found that the County had met its relatively light burden of showing a possible defense. In particular, the court found it possible that the plaintiffs had not identified a policy, custom, or practice that caused an alleged constitutional violation, and that statute-of-limitations or other defenses might apply. The court did not decide whether those defenses would succeed.

The court found no prejudice to the plaintiffs from the County’s delay of a few weeks. The plaintiffs had recently filed an amended complaint and did not identify any potential prejudice in response to the motion.

Disposition

Judge Tiga granted the County’s motion to set aside entry of default. The County must respond to the plaintiffs’ amended complaint within the time allowed by the Federal Rules of Civil Procedure.