Graham v. Brown

[¶ 1] Shyam Brown appeals from a default judgment entered in the District Court (Skowhegan, Kelly, J.) awarding Sarah Graham $50,000 in compensatory damages and $5000 in punitive damages for intentional infliction of emotional distress after an entry of default on the issue of liability and a hearing on the issue of damages. Brown contends that (1) the court abused its discretion in declining to set aside the entry of default; (2) the court erred in entering the default judgment because the evidence did not support, and the court did not expressly find, each element of the tort of intentional…