Spitzer v. Spitzer
In Spitzer v. Spitzer, 777 P.2d 587 (Wyo. 1989), the district court entered a default judgment in a divorce action because the husband had refused to comply with the court's discovery orders.
However, it also awarded the wife certain real and personal property which went beyond the general relief sought in the complaint without any evidentiary proceedings.
The Court held "Only in those situations where the damages sought are liquidated and claimed in the complaint may the court grant relief without further proceedings." Id. at 592.
Where damages or relief are unliquidated or not specified with certainty in the complaint, further proceedings are indicated pursuant to W.R.C.P. 55(b)(2).
Specifically, in issuing a divorce decree pursuant to a default judgment, the Court held the district court was required to comply with statutory criteria applicable to the distribution of marital property. Spitzer, 777 P.2d at 593.