When will a court grant a default judgment for failure to obtain discovery?

That is not to say a default judgment would have been a proper sanction. It would have placed the Shermans in a better position than if discovery had been obtained in the first place. (See, e.g., McGinty v. Superior Court, supra, 26 Cal.App.4th at p. 210 ["The courts [ ] frown upon the extreme sanction of dismissal of a case for failure to make discovery, and recommend instead lesser sanctions of fines."].) But the trial court denied the motion for sanctions on the ground it could not grant relief after the conclusion of the trial, thus it did not consider the merits of the request. It should have reached the merits and found monetary sanctions absolutely mandated.