Alken-Ziegler, Inc v. Waterbury Headers Corp
In Alken-Ziegler, Inc v. Waterbury Headers Corp, 461 Mich 219; 600 NW2d 638 (1999), the Supreme Court clarified the showing a movant must make in order to be entitled to have a default or a default judgment set aside.
Manifest injustice is the result that would occur if a default were allowed to stand even though a party has satisfied the meritorious-defense and good-cause requirements of MCR 2.603(D)(1). Id. at 233.
If a party puts forth a meritorious defense and then attempts to satisfy the good-cause requirement by demonstrating the existence of a procedural irregularity or a reasonable excuse for failure to comply with the requirements that created the default, the strength of the defense affects the good-cause showing that is necessary. Id.
If the party states a meritorious defense that would be absolute if proven, a lesser showing of good cause is required. Id. at 233-234.