TURQUOISE WYLIE v. GLENNCREST., 143 A.3d 73

Background

Tenant Turquoise Wylie lived in a Glenncrest townhouse for ~8 years; landlord sued for nonpayment of rent (Jan–Jun 2014).
Wylie appeared at the July 2014 initial hearing; parties sought a one-month continuance. She did not appear at the August further initial hearing; court entered default and scheduled an ex parte proof hearing.
Wylie did not attend the September ex parte proof hearing; landlord’s property manager testified and the court entered a redeemable judgment for possession and a Trans-Lux amount; Wylie was evicted September 30, 2014.
In December 2014 Wylie (pro se) filed a Rule 60(b) motion to vacate the default judgment, an answer, and related relief; she claimed she did not owe the alleged six months of back rent and had payment records and an out‑of‑court settlement agreement.
At the January 2015 hearing the trial court denied Rule 60(b) relief without taking testimony or admitting Wylie’s documents, relying largely on the fact she missed the August hearing and on finality/prejudice to the landlord.
On appeal the D.C. Court of Appeals reversed and remanded, finding the trial court abused its discretion by failing to hold an adequate evidentiary hearing and by misapplying the Rule 60(b) factors.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the default judgment should be vacated under Rule 60(b)	Wylie: she acted in good faith, sought help, filed promptly after eviction, has records showing rent paid (prima facie defense), and may not have received notice of the ex parte hearing	Glenncrest: Wylie failed to appear at August hearing; judgment and eviction already executed; unit re‑rented; vacatur would prejudice landlord	Reversed and remanded — trial court abused discretion by denying relief without evidentiary hearing and by overemphasizing finality over merits inquiry
Whether the trial court erred by not allowing testimonial or documentary proof at the Rule 60(b) hearing	Wylie: court prevented her from presenting witnesses and rent records to resolve credibility and factual disputes	Glenncrest: relied on ex parte proof hearing record and counsel’s statements; argued Wylie delayed and unit was re‑rented	Held: court must conduct meaningful inquiry and hold evidentiary hearing when material factual disputes and credibility determinations are required
Whether Wylie acted promptly and in good faith after default and eviction	Wylie: sought counsel, used Landlord‑Tenant Resource Center, filed Rule 60(b) ~3 months after eviction given hardships (work, single parent)	Glenncrest: delay (90 days) after eviction; argued prejudice and that Wylie admitted some debt	Held: trial court improperly minimized Wylie’s circumstances; three months may be reasonable; promptness and good faith require factual development on remand
Whether vacatur would prejudice the landlord	Wylie: no guarantee she would prevail; other remedies may mitigate any prejudice	Glenncrest: unit re‑rented; vacatur would require displacing new tenants and cause prejudice	Held: trial court overstated prejudice; prejudice must be assessed with record and is not dispositive where movant shows meritorious defense

Key Cases Cited

Starling v. Jephunneh Lawrence & Assocs., 495 A.2d 1157 (D.C. 1985) (courts favor trial on the merits; even slight abuse in refusing to set aside default may justify reversal)
Carrasco v. Thomas D. Walsh, Inc., 988 A.2d 471 (D.C. 2010) (articulates five‑factor Rule 60(b) inquiry and requires thorough inquiry when facts are disputed)
Westmoreland v. Weaver Bros., Inc., 295 A.2d 506 (D.C. 1972) (default should be set aside absent willful neglect if prima facie defense exists and no prejudice)
Panici v. Rodriguez, 689 A.2d 557 (D.C. 1997) (failure to appear does not warrant dismissal where no showing of willful, deliberate delay)
Jones v. Hersh, 845 A.2d 541 (D.C. 2004) (standard of review: setting aside default is within trial court’s discretion; Rule 60(b)(4) review de novo for void judgments)