Pablo Gonzalez v. Quoc Nguyen, 414 P.3d 1163

On April 9, 2012, Quoc Nguyen rear‑ended Pablo Gonzalez; police reported a low‑speed (10 mph) impact and either no or possible injury.
Gonzalez sued Nguyen and Dysart Hotel (employer/owner) for negligence; Dysart failed to file a responsive pleading despite communications routed through its claims adjuster and a pre‑suit demand.
After a default was entered, the trial court awarded Gonzalez $667,279.56 in damages following a hearing where Defendants did not appear.
Defendants (Dysart and insurer Companion) moved under Ariz. R. Civ. P. 60(c)(6) to vacate the damage award; Dysart’s counsel said liability would be admitted but damages were contestable if relief were granted.
The trial court granted the motion to vacate, citing doubts that the damage award was excessive and preferring resolution on the merits; the court of appeals reversed, holding Dysart failed to show a meritorious defense supported by evidence outside the record.
The Arizona Supreme Court granted review and reversed the court of appeals, holding a defendant may rely on the existing record to show a meritorious defense and that trial courts have broad discretion under Rule 60(c)(6).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a defendant moving under Rule 60(c)(6) must present evidence outside the existing record to show a meritorious defense	Gonzalez: prior cases require extrinsic evidence; Companion’s affidavit was insufficient	Dysart: meritorious defense may be shown by the existing record (police report, counsel affidavit showing much lower special damages); no extra‑record evidence required	Court: No extra‑record evidence requirement; a meritorious defense may be shown from the existing record and trial courts have broad discretion to decide on the merits
Whether lack of excusable neglect under Rule 60(c)(1) bars relief under Rule 60(c)(6)	Gonzalez: absence of excusable neglect weighs against vacatur	Dysart: clauses are separate; relief under (6) may be appropriate even if (1) is not met	Court: Clauses are mutually exclusive; lack of excusable neglect does not automatically preclude (6) relief
Standard for showing a meritorious defense in Rule 60(c)(6) proceedings	Gonzalez: higher showing required; court of appeals applied stricter test	Dysart: only a minimal showing is required—some legal justification and substantial evidence, not mere speculation	Court: The burden is minimal but greater than speculation; courts may vacate when record suggests damages are excessive and merits should be decided

Moreno v. Jones, 213 Ariz. 94 (Court’s standard of abuse of discretion review)
Daou v. Harris, 139 Ariz. 353 (1984) (law favors resolution on the merits when trial court has doubt about vacating a default)
Webb v. Erickson, 134 Ariz. 182 (1982) (Rule 60(c)(6) provides broad equitable power; clauses are mutually exclusive)
Union Oil Co. of Cal. v. Hudson Oil Co., 131 Ariz. 285 (1982) (meritorious defense requires facts which, if proven at trial, would constitute a defense)
Richas v. Superior Court, 133 Ariz. 512 (1982) (motion must show some legal justification and substantial evidence)
United States v. Aguilar, 782 F.3d 1101 (9th Cir. 2015) (meritorious‑defense burden described as minimal)