Bonner v. American Financial Marketing Corp

In Bonner v. American Financial Marketing Corp., 181 Conn. 57, 434 A.2d 323 (1980), because the rules of practice required that a motion for judgment be made after a default is ordered, the trial court, without a motion for judgment, improperly render judgment for the plaintiff. Id. Thus, in Bonner our Supreme Court concluded that the trial court should have granted the defendant's motion to open the judgment. The court reasoned that the purpose of the rule of practice that required a motion for judgment to follow a motion for default was to put the defendant on notice that if it failed to take any action to protect its interest, it risked the entry of a judgment against it. Id., 57-58.