Sass

*444 *1034 When a plaintiff files a lawsuit, the defendant can opt not to respond; the result is a default judgment for the plaintiff. ( *1035 Code Civ. Proc., §§ 580, subd. (a), 585, subds. (a) & (b).) 1 However, the relief awarded in such a default judgment "cannot exceed" the "type and amount of relief" sought in the plaintiff's operative pleadings. ( § 580, subd. (a) ; Becker v. S.P.V. Construction Co. (1980) 27 Cal.3d 489 , 493-494, 165 Cal.Rptr. 825 , 612 P.2d 915 ( Becker ).) This case presents two unsettled questions: (1) May a default judgment be entered for an amount in excess of the demand in the operative pleadings when the plaintiff seeks an accounting or valuation of a business; and (2) Should the comparison of whether a default judgment exceeds the amount of compensatory damages demanded in the operative pleadings examine the aggregate amount of non-duplicative damages or instead proceed on a claim-by-claim or item-by-item basis? We hold that actions alleging an accounting claim or otherwise involving the valuation of assets are not excused from limitations on default judgments and, in so doing, add our voice to the growing chorus of cases so holding. We also hold…