context: Cases discussing the "due process" limitation on a court's inherent powers do not explicitly define the substantive content of those limitations. That said, however, the key factor in determining whether the entry of default violates due process appears to be whether the conduct for which default was entered related to the merits of the case, or only to a peripheral matter.
citation_a.signal: cf.
citation_a.identifier: 666 F.2d 414, 416-17
citation_a.parenthetical: finding that default judgment against defendant for failure to pay a fine when the defendant had complied with an order to give a deposition was punitive and a violation of due process as the court could not presume that the case lacked merit
citation_a.sentence: Cf. SEC v. Seaboard Corp., 666 F.2d 414, 416-17 (9th Cir.1982) (finding that default judgment against defendant for failure to pay a fine when the defendant had complied with an order to give a deposition was punitive and a violation of due process as the court could not presume that the case lacked merit).
citation_b.signal: see
citation_b.identifier: 826 F.2d 917, 917
citation_b.parenthetical: upholding lower court's entry of default where appellant's perjury "infected all of the pretrial procedures and interfered egregiously with the court's administration of justice" and "greatly disadvantaged the plaintiffs who had planned their strategy and developed then-case to respond to [appellant's] false evidence"
citation_b.sentence: See, e.g., TeleVideo, 826 F.2d at 917 (upholding lower court’s entry of default where appellant’s perjury “infected all of the pretrial procedures and interfered egregiously with the court’s administration of justice” and “greatly disadvantaged the plaintiffs who had planned their strategy and developed then-case to respond to [appellant’s] false evidence”).