William L. Lopez v. Samantha Ritter

Summary

The Wyoming Supreme Court affirmed the district court's entry of default judgment against William Lopez in favor of Samantha Ritter following a 2015 car accident. The court held that Lopez waived his due process challenge to service at a known vacant address by failing to raise it below, but addressed the jurisdictional question of whether Ritter exercised due diligence before invoking substituted service under Wyoming's nonresident motorist statute, concluding she did. The court further held it lacked jurisdiction to review the district court's reinstatement of the case after dismissal without prejudice because Lopez's notice of appeal did not designate that order, and it found no abuse of discretion in the denial of Lopez's Rule 60 motion for relief from the default judgment.