A drywall contractor that went silent for months on a $65,298 insurance premium debt has lost its appeal over the speed of the resulting judgment. 

Wesco Insurance Company had provided workers' compensation and employer's liability coverage to Martins Drywall, LLC across three consecutive policy periods running from July 2020 to April 2023. After final audits, Wesco invoiced the contractor $32,881 for the first period, $19,882 for the second and $12,535 for the third. Martins Drywall never paid. 

Wesco filed suit in Connecticut Superior Court in October 2023. The contractor's counsel entered an appearance, secured a two-week extension to respond, and then went quiet. No answer. No motion. Nothing. By February 2024, Wesco had moved for default, and the clerk granted it on February 16. 

Connecticut's Practice Book § 17-32(b) ordinarily requires a plaintiff to wait 15 days after default before filing for judgment. Wesco filed its motion just seven days later, on February 23, attaching an affidavit of debt that itemized the unpaid invoices and added $426.63 in costs for a total of $65,724.63. The trial court granted the motion on March 18, 2024, with postjudgment interest at 6% per year and an order for weekly payments of $35. 

Martins Drywall surfaced in April 2024 with a motion to reargue. Its counsel said he had been unaware of the default due to an email system issue. The contractor conceded liability but argued the damages might be miscalculated. The trial court denied the motion. 

On appeal, the contractor pressed the timing argument. Connecticut's Appellate Court, in a decision officially released September 22, 2026, disagreed. The panel pointed to Practice Book § 17-33(b), which eliminates the 15-day waiting period for certain categories of cases, including any contract action where damages are liquidated. Because Wesco's claim was built on specific invoices for defined policy periods, the amounts were ascertainable by straightforward math from documents the contractor already had. That made them liquidated damages under long-standing state precedent. 

The contractor argued that § 17-33(b) applies only to foreclosures, summary process actions and promissory notes. The court found that contention without merit, noting the rule's plain language covers any contract action with liquidated damages. 

The court also rejected the contractor's argument that a 15-day window protects a defendant's right to cure a default, pointing to the competing interest in resolving established debts efficiently when a party has done nothing to engage. 

For premium recovery and collections teams, the decision reinforces that unpaid premium claims backed by itemized invoices can qualify for expedited default judgment in Connecticut - and that procedural inaction carries real consequences.