Bellow v. State of Nevada, 2:25-cv-00024

Plaintiff Armanna J. Bellow, proceeding pro se, filed a motion seeking default judgment against the State of Nevada.
The Clerk of Court previously granted the Plaintiff's motion for entry of clerk’s default due to Defendant’s lack of response to the summons.
The Court had denied Bellow's earlier motions for default and default judgment, citing improper service of process on the Defendant.
Plaintiff then filed the present motion, which the Court construes as a motion for reconsideration under Federal Rule of Civil Procedure 60(b).
Under Rule 55, default judgment is a two-step process: (1) clerk’s default and (2) court’s default judgment, contingent upon proper service.
The Court reviews whether Bellow presented new arguments or circumstances justifying reconsideration of the default judgment denial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Court should reconsider denial of default judgment due to entry of clerk's default	Bellow argues default judgment should be granted since clerk's default was entered and State of Nevada did not respond.	Nevada did not appear; main argument is adequacy of service, per the court.	Court held default judgment inappropriate due to improper service; no grounds for reconsideration.

Erickson v. Pardus, 551 U.S. 89 (2007) (documents filed pro se are to be liberally construed)
Symantec Corp. v. Global Impact, Inc., 559 F.3d 922 (9th Cir. 2009) (explaining two-step process for default judgment under Rule 55)
Backlund v. Barnhart, 778 F.2d 1386 (9th Cir. 1985) (motion for reconsideration must present new arguments to be granted)
Twentieth Century-Fox Film Corp. v. Dunnahoo, 637 F.2d 1338 (9th Cir. 1981) (Rule 60(b)(6) relief is only available in extraordinary circumstances)