What is the test for default judgment in a personal injury matter?

For a default judgment to satisfy the "actually litigated" requirement, the record in the prior proceeding must show an express finding upon the allegation for which preclusion is sought. However, "the express finding requirement can be waived if the court in the prior proceeding necessarily decided the issue. As a conceptual matter, if an issue was necessarily decided in a prior proceeding, it was actually litigated." Harmon v. Kobrin (In re Harmon), supra, 250 F.3d at 1248.