irvin v palmer 580 sw3d 15

Citation: Irvin v. Palmer, 580 S.W.3d 15

This Missouri appellate case addressed whether a company could set aside a default judgment that was entered against it more than one year earlier in an employment discrimination lawsuit. Celestina Gamez sued her former employer, EasyEx MO OFallon, LLC, claiming violations of the Missouri Human Rights Act and Workers' Compensation Law. After EasyEx was properly served but failed to respond, the trial court entered a default judgment in March 2024 awarding Gamez damages and attorney's fees. EasyEx did not attempt to challenge this judgment until April 2025—over one year later—when Gamez began collection efforts. The Court of Appeals affirmed the trial court's denial of EasyEx's motion to set aside the default judgment. Under Missouri Rule 74.05(d), parties seeking to overturn a default judgment must act "within a reasonable time not to exceed one year after the entry of the default judgment." The court rejected EasyEx's argument that the one-year deadline should run from when they received notice of the judgment rather than when it was entered, emphasizing that defaulting parties forfeit their right to notice under Missouri law. The court also awarded Gamez attorney's fees for defending the appeal, since she was the prevailing party under the Missouri Human Rights Act. This decision reinforces that Missouri's one-year deadline for challenging default judgments is strictly enforced and cannot be extended based on claims of lack of notice. For businesses and other litigants, this case underscores the critical importance of maintaining current contact information with registered agents and monitoring for potential lawsuits. Once a default judgment is entered, parties have limited time to act, and waiting until collection efforts begin is likely too late to seek relief from the court.

Citation: Irvin v. Palmer, 580 S.W.3d 15

Citation: Irvin v. Palmer, 580 S.W.3d 15

Citation: Irvin v. Palmer, 580 S.W.3d 15

Citation: Irvin v. Palmer, 580 S.W.3d 15

Citation: Irvin v. Palmer, 580 S.W.3d 15

Citation: Irvin v. Palmer, 580 S.W.3d 15

Citation: Irvin v. Palmer, 580 S.W.3d 15

Citation: Irvin v. Palmer, 580 S.W.3d 15

Citation: Irvin v. Palmer, 580 S.W.3d 15

Citation: Irvin v. Palmer, 580 S.W.3d 15

Citation: Irvin v. Palmer, 580 S.W.3d 15

Citation: Irvin v. Palmer, 580 S.W.3d 15

Citation: Irvin v. Palmer, 580 S.W.3d 15

Citation: Irvin v. Palmer, 580 S.W.3d 15

Citation: Irvin v. Palmer, 580 S.W.3d 15