Background
Traci D. Swindle and Keelie M. Gaddis sued Lacey Collingsworth Carpenter, individually and doing business as Honky Tonk Frenchies, LLC, over a French bulldog breeding arrangement. They alleged that they paid Carpenter $6,000 to acquire and co-own CoCo, with breeding costs and profits to be divided equally. Their petition also alleged disputes concerning proceeds and future payments connected to puppies from CoCo’s litter, including Crewz and TBO, and asserted an interest in another dog, Joplin.
After Carpenter did not answer, the trial court confirmed a default judgment. It awarded plaintiffs $13,000, declared them sole owners of CoCo, Alex, and Remi, gave them full ownership of Alex in exchange for waiving future Joplin revenues, and ordered Carpenter to provide paperwork for sole AKC registration. Carpenter appealed.
The Court’s Holding
The First Circuit reversed the July 2, 2025 default judgment. A default judgment may not differ in kind from the relief requested in the petition, and damages must be proven as properly due. The ownership and AKC-registration relief exceeded the petition, which did not seek to make plaintiffs sole owners of CoCo, Alex, or Remi or request the Alex-for-Joplin-revenues exchange.
The court also held that plaintiffs did not establish a prima facie case for the $13,000 award. The awards for Crewz and TBO did not match the unpaid amounts supported by testimony; the alleged oral Joplin arrangement lacked corroborating evidence and proof of breach; and the claimed $5,000 in future Koi Boi stud fees was speculative.
Key Takeaways
- Default relief must stay within the kind of relief requested in the petition.
- A plaintiff must prove the amount of damages properly due, not merely allege loss.
- Speculative future breeding revenue cannot support a default-damages award.
Why It Matters
The decision underscores that a default confirmation hearing is not an opportunity to obtain broader ownership remedies or unproven damages than the pleadings placed at issue. Even when a defendant does not appear, due process requires notice of the requested relief and competent proof supporting each component of the judgment.