Wise Moving & Storage, Inc. v. Rieser-Roth

Phipps, Judge.

Wise Moving & Storage, Inc. appeals a default judgment awarding Dorothy Rieser-Roth actual and punitive damages. Wise claims that the trial court erred in failing to specially find that punitive damages were awardable and in failing to hold a hearing on the amount of damages. Although we find no error in the form of the punitive damages award, we vacate the judgment and remand for farther proceedings because the record is unclear on the question of whether a hearing on damages was held.

In her complaint against Wise, Rieser-Roth alleged that she had hired Wise to transport…