In Re the Marriage of Lesley Marie Dorland and Kevin Leroy Dorland Upon the Petition of Lesley Marie Dorland, and Concerning Kevin Leroy Dorland, 16-0132

Lesley Dorland filed for dissolution on June 17, 2015; Kevin was served by deputy sheriff on June 23 and did not answer or appear.
Kevin previously refused an earlier copy (Lesley testified he burned a copy; Kevin did not deny receiving papers) and acknowledged the deputy left the service at his residence.
Lesley’s counsel mailed a notice of intent to take default on September 22 and moved for default on October 6; the district court entered a default decree October 8 dividing property and awarding spousal support.
Lesley had provided Kevin proposed decrees on at least three occasions before the decree was entered.
Kevin filed a motion to set aside the default judgment on November 24 (through counsel), citing mistake, inadvertence, excusable neglect, medical-related memory issues, and surprise at the decree’s allegedly harsh terms; a hearing was held December 17.
The district court found Kevin willfully ignored notices, discredited his testimony about not receiving papers, denied the motion to set aside, and the Court of Appeals affirmed. Appellate attorney fees were requested but denied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the default decree should be set aside under Iowa R. Civ. P. 1.977 (mistake, inadvertence, surprise, excusable neglect, unavoidable casualty)	Lesley: Default was proper; Kevin had notice and opportunities and ignored them	Kevin: Medical-related memory/concentration lapses and surprise at harsh decree constitute good cause	Court: Affirmed denial — Kevin willfully ignored notices, had prior access to proposed decree, did not act promptly, failed to prove good cause
Whether appellate attorney fees should be awarded to Lesley	Lesley: Seeks fees based on needs, ability to pay, and merits	Kevin: (implicitly) appeal lacked sufficient merit to justify fees	Court: Declined to award appellate fees after considering factors

Sheeder v. Boyette, 764 N.W.2d 778 (Iowa Ct. App. 2009) (standard and discretion for setting aside default judgments)
Brandenburg v. Feterl Mfg. Co., 603 N.W.2d 580 (Iowa 1999) (willful disregard of procedure supports denial of relief)
Haynes v. Ruhoff, 157 N.W.2d 914 (Iowa 1968) (ignorance of legal process does not excuse failure to act)
In re Marriage of Cutler, 588 N.W.2d 425 (Iowa 1999) (motion to set aside default is tried at law; appellate review principles)
Wilson v. Liberty Mut. Group, 666 N.W.2d 163 (Iowa 2003) (doubts resolved in favor of setting aside default, but movant bears burden)
Cent. Nat’l Ins. Co. of Omaha v. Ins. Co. of N. Am., 513 N.W.2d 750 (Iowa 1994) (definition of "good cause")