Sunshine Security & Detective Agency v. Wells Fargo Armored Services Corp.

This is an appeal by the defendant Sunshine Security and Detective Agency [Sunshine] from a final default judgment entered against it in the trial court. The defendant Sunshine urges that the trial court erred in entering the default judgment below because, inter alia, the original complaint, on which the default was based, wholly failed to state a cause of action against it. We entirely agree and reverse based on the following briefly stated legal analysis.

First, the law is well-settled that a default judgment may not be entered against a defendant on a complaint which wholly fails to state…