Small Claims & Default Judgments-Motion to Reopen Default Judgment

WISCONSIN LAW JOURNAL STAFF//February 24, 2025//

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WI Court of Appeals – District I

Case Name: Milwaukee Board of School Directors v. Gevonchai L. Hudnall

Case No.: 2024AP000667

Officials: Colón, J.

Focus: Small Claims & Default Judgments-Motion to Reopen Default Judgment

Hudnall, a former teacher with the Milwaukee Public Schools, appealed a judgment in favor of the Milwaukee Board of School Directors, which sought $3,000 in liquidated damages due to Hudnall’s resignation during the school year. The Board filed a small claims action, and when Hudnall failed to attend the trial, the circuit court entered a default judgment in favor of the Board. Hudnall appealed, arguing the Board breached the contract first, making it void.

The court ruled that under Wisconsin law, no appeal can be made from a default judgment. The only recourse would have been for Hudnall to file a motion to reopen the default judgment in the circuit court. Since Hudnall failed to seek this motion, the court had no authority to review the judgment.

Dismissed.

Decided 02/18/25

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