In re Marriage of Howard

The trial court defaulted respondent as a discovery sanction for his refusal to produce complete and updated copies of his financial records in a divorce case and then entered a default dissolution judgment. The trial court also denied respondent’s motion to vacate the default judgment and respondent appealed. The appellate court affirmed, finding that the balance of hardships favored leaving the default judgment intact and that the trial court’s denial of respondent’s motion to vacate accomplished substantial justice and was not an abuse of discretion. (D.B. WALKER and ELLIS, concurring)