What is the standard of review for an appeal from a default judgment?

California, United States of America


The following excerpt is from Lancaster v. Law Offices of Isabel Hernandez Rodriguez, B256990 (Cal. App. 2015):

Uva v. Evans (1978) 83 Cal.App.3d 356, 363-364, involving an appeal from a default judgment, sets forth the pertinent standard of review: "The power of an appellate court to review the trier of fact's determination of damages is severely circumscribed. An appellate court may interfere with that determination only where the sum awarded is so disproportionate to the evidence as to suggest that the verdict was the result of passion, prejudice or corruption [citations] or where the award is so out of proportion to the evidence that it shocks the conscience of the appellate court. [Citations.]"

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