Sycamore Hills Estates Homeowners Ass’n., Inc. v. Zablotny – 1/20/2021
Arizona Court of Appeals Division Two holds that the superior court has jurisdiction to enter a stipulated judgment that includes relief not requested in the underlying complaint.
A homeowner filed a complaint against a homeowners association alleging that the HOA had breached the CC&Rs that govern the HOA. The HOA and the homeowner settled the litigation, including a stipulated final judgment that incorporated the terms of the agreement. The HOA later sought to void the judgment under Rule 60(b)(4), arguing that the court lacked jurisdiction to in effect enter a declaratory judgment that the settlement agreement is a valid agreement. The superior court denied the motion.
The Court of Appeals affirmed. Under Rule 60(b)(4), a party may seek relief from a “void” judgment when the “court entering it lacked jurisdiction” over the subject matter, the person, or “to render the particular judgment.” A court’s jurisdiction to enter a particular judgment “is limited by the nature of the suit, and the issues raised by the pleadings.” A court may not, for example, enter a civil money damages judgment for a debt in a contested family court child-support proceeding. When a court has authority to hear an underlying dispute and the parties agree to a stipulated judgment, however, the court has jurisdiction “to render the particular judgment.” For instance, in a forcible entry and detainer action, the court has authority to approve of a stipulated judgment that includes a damages award for past-owed rent. Accordingly, the superior court had authority to approve of the validity of the settlement agreement in this case, even if the homeowner’s original complaint did not request declaratory relief to that effect.
Judge Brearcliffe authored the opinion; Judge Eppich and Chief Judge Vasquez joined.