CIT BANK, N.A. VS. RONALD WEAKLY (F-030884-15, OCEAN COUNTY AND STATEWIDE), A-4272-15T2

Plaintiff CIT Bank, N.A. obtained final judgment in foreclosure against Ronald Weakly and his wife after the Chancery Division denied defendants' motion to vacate a default.
The trial judge entered the denial order without oral argument and stated only that the decision was "for the reasons set forth in [p]laintiff's opposition," providing no independent findings of fact or conclusions of law.
Defendants appealed pro se, arguing the court abused its discretion by denying the motion without adequate reasoning.
The Appellate Division reviewed the record and found the trial judge failed to comply with Rule 1:7-4, which requires a judge to state findings of fact and conclusions of law in non-jury actions.
The appellate court concluded it could not perform meaningful review because the trial judge did not explicitly adopt or analyze the parties’ submissions or make independent findings.
The judgment and order were vacated and the matter was remanded for reconsideration of the motion; the trial judge was directed to enter a new order within fourteen days accompanied by a written or oral statement of reasons complying with Rule 1:7-4.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by denying the motion to vacate default	The court relied on plaintiff's opposition and properly denied relief	The denial lacked findings and therefore was an abuse of discretion	Remanded: court failed to comply with Rule 1:7-4; appellate court cannot review without reasons
Whether a judge may rely on a party's submitted reasons without independent findings	Plaintiff's opposition supplied sufficient reasons for denial	Judge must make explicit reliance and independent determination	A judge can rely on a party's reasons only if that reliance is made explicit and accompanied by the judge's own findings
Proper remedy when trial court fails to state reasons	Affirm denial and permit enforcement	Vacate and remand for statement of reasons or reconsideration	Vacated and remanded for reconsideration and a statement of reasons; directed reconsideration within 14 days

In re Tr. Agreement Dec. 20, 1961, by & between Johnson & Hoffman, Lienhard & Perry, 399 N.J. Super. 237 (App. Div. 2008) (discusses judge's obligation under Rule 1:7-4 and limits on relying on party submissions)
Avelino-Catabran v. Catabran, 445 N.J. Super. 574 (App. Div. 2016) (requires clear factual findings correlated to legal conclusions)
Monte v. Monte, 212 N.J. Super. 557 (App. Div. 1986) (explains need for articulated reasons to avoid arbitrary decisions)
Allstate Ins. Co. v. Fisher, 408 N.J. Super. 289 (App. Div. 2009) (judge may rely on party's proposed findings only if reliance is explicit)
O'Brien v. O'Brien, 259 N.J. Super. 402 (App. Div. 1992) (stresses that articulation of reasons is essential to fair resolution)