April 6, 2026
Court of Appeal, First Appellate District, Division Four
The Rule of In re Marriage of Jenkins is that a default judgment in a family law case must be set aside when it exceeds the relief requested in the petition and the defaulting party lacked adequate notice of the specific assets to be divided, under circumstances where the petition contained only "TBD" placeholders for property division and the prove-up hearing was conducted based on informal, off-the-record communications without proper notice to the defaulting spouse.
March 18, 2026
Court of Appeal, First Appellate District, Division Four
The Rule of In re Marriage of Jenkins is that a default judgment in dissolution proceedings that awards specific property division relief exceeds the relief requested where the dissolution petition listed all property division issues as "To be determined," under circumstances where the defaulted party lacked proper notice of the prove-up hearing and the specific property division being sought.
3/18/26
Court of Appeal of the State of California, Fourth Appellate District, Division Three
The Rule of Dion v. Weber is that under the Victims of Corporate Fraud Compensation Fund statutory scheme, trial courts are precluded from relitigating the merits of underlying fraud judgments when evaluating payment claims from the fund, under circumstances where the Secretary of State denies payment based on challenges to the validity of the original fraud judgment.