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Understanding 'Sum Certain' in Default Judgments: Insights from Gleich & Associates v Gritsipis

Understanding the legal complexities of default judgments can be daunting, especially when the claims involve a mix of specific and general damages. In the New York legal system, the criterion of "sum certain" plays a pivotal role when clerks enter default judgments. But what happens when not all claims in a lawsuit fit this criterion?

Simplifying 'Sum Certain'

A "sum certain" refers to a specific, unequivocal amount of money claimed. It is straightforward when a debt's value is undisputed and clear-cut, such as a fixed loan repayment. However, when claims involve subjective valuations, like the worth of services rendered, determining a "sum certain" becomes more complex.

Case Breakdown

In the notable case of Stephen B. Gleich & Associates v Gritsipis, the courts grappled with this issue. A law firm's claims for unpaid fees, unjust enrichment, and account stated were under scrutiny. The court determined that not all claims were for a "sum certain," leading to a pivotal decision that affects how certain types of claims must be processed in court.

Implications for Default Judgments

The Gritsipis case reminds us that when claims lack a "sum certain," a judge—not a clerk—must review the default judgment. This provides an important strategy for those seeking to challenge such judgments.


For individuals contending with a default judgment involving mixed claims, Gritsipis offers a valuable precedent. It's a reminder that the specificity of your claim matters and that even when a judgment is vacated, the battle may not be over. A defendant must still demonstrate a reasonable excuse and a legitimate defense for failing to respond to the original lawsuit to avoid liability.


If you're facing a default judgment with varied claims, understanding the nuances of "sum certain" and leveraging cases like Gleich & Associates v Gritsipis can be crucial. For legal guidance tailored to your situation, consider consulting with a knowledgeable attorney.

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