Americhoice Fed. Credit Union v. Ross, R., 135 A.3d 1018

AmeriChoice filed a mortgage-foreclosure complaint against Homeowners on May 9, 2012 and sought a default judgment later.
Homeowners, pro se, filed preliminary objections; the trial court sustained AmeriChoice’s objections and required an answer within 20 days.
AmeriChoice mailed a Notice of intention to file a praecipe for default judgment on May 23, 2013 and filed a praecipe for default judgment on June 4, 2013.
The Notice stated: “You are in default because you have failed to take action required of you in this case,” without detailing specific default reasons.
The prothonotary entered default judgment on June 4, 2013 for $113,998.57 plus costs, and Homeowners later filed multiple petitions to strike the judgment.
The trial court denied the petitions to strike; Homeowners appealed, challenging the Notice under Pa.R.C.P. 237.1 and 237.5, arguing it was defective on its face.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether AmeriChoice’s Notice complies with Rule 237.1/237.5.	Homeowners argue the notice is facially defective for failing to state specific reasons for default.	AmeriChoice contends the notice substantially complies and attached orders addressed the case.	Notice defective; reversal and remand.

Oswald v. WB Pub. Square Assocs., LLC, 80 A.3d 790 (Pa. Super. 2013) (defective on its face when generic default language lacks specific reasons)
City of Philadelphia v. David J. Lane Adver., Inc., 33 A.3d 674 (Pa. Cmwlth. 2011) (form and specificity requirements for default notices under Rule 237.5)
Township of Chester v. Steuber, unreported (Pa. Cmwlth. 1983) (context for Rule 237.5 amendments and notice requirements)
Green Acres Rehab. & Nursing Ctr. v. Sullivan, 113 A.3d 1261 (Pa. Super. 2015) (reaffirmation of standards governing petitions to strike default judgments)
Attix v. Lehman, 925 A.2d 864 (Pa. Super. 2007) (default judgments disfavored unless validly entered)