Scanlan v. San Francisco County Department of Social Services

How later courts describe this case

• vacating default judgment where plaintiffs claims were “either facially invalid or utterly unsupported,” defendant had meritorious defense, and prejudice was not shown
• granting motion to set aside default judgment and sua sponte dismissing complaint for failure to state a claim upon which relief may be granted
• upholding district court’s decision to vacate default judgment even though movant’s default was willful
• "[T]he calculation of damages was preposterous.... [The] underlying claims were either facially invalid or utterly unsupported.... Allowing the default judgment to stand would ... have constituted a serious miscarriage of justice"
• District Court could impose mandatory minimum sentence under 21 U:S.C. §§ 841, 841(a)(1), 841(b)(l)(B)(vii), 846, upon determination of the quantity of marijuana plants based on preponderance of the evidence at time of sentencing