Trial Court Judge Orders Opening of a Snap Default Judgment

In the case of Susquehanna Legal Aid For Adults & Youth v. Winkleman, No. CV-2024-01041 (C.P. Lyc. Co. Sept. 23, 2025 Carlucci, J.), Judge William P. Carlucci of the Lycoming County Court of Common Pleas granted a Plaintiff’s Petition to Open a Defendant’s default judgment filed relative to the Defendant’s counterclaim where the court found that the Defendants had entered a “snap” default judgment.

In ruling upon the Plaintiff’s Petition to Open and/or Strike the default judgment, the court reviewed the standard of review which required the court to determine (1) whether the default was excusable; (2) whether the parties seeking to open the judgment has shown a meritorious defense or claim, and (3) whether the Petition to Open has been promptly filed.

The court also noted that it “sincerely believe[d]” that the Rules of Civil Procedure are not intended to become a “bag of tricks.” See Op. at 5. 

In so noting, the court also referred to Pa. R.C.P. 126 of the Pennsylvania Rules of Civil Procedure that requires the rules to be liberally applied to secure the just, speedy and inexpensive determination of every action. Judge Carlucci noted that, under that rule, a court is, at every stage of the action, permitted to disregard any error or defect of procedure that does not affect the substantive rights of the parties.

Judge William P. Carlucci
Lycoming County 

Judge Carlucci additionally noted that it is the well-settled law of the Commonwealth of Pennsylvania that “snap judgments” are heavily disfavored.

According to the record before the court in this case, forty-one (41) minutes after the Defendants electronically filed their default judgment on their counterclaim against the Plaintiff, the Plaintiff had electronically filed their Preliminary Objections to the Defendants’ counterclaim.

Judge Carlucci noted that, had counsel for the Defendants made any effort to contact counsel for the Plaintiff before taking the default judgment, counsel for the Defendant would have learned that a responsive pleading was only minutes away from being filed.

Based upon the record before the court, the court found that the Petition to Open or Strike was promptly filed and was worthy of being granted. As such, the court opened the default judgment and directed the Plaintiff to file its responsive pleading.

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Source: The Legal Intelligencer Common Pleas Case Alert, www.Law.com (Nov. 6, 2025).