U.S. SUPREME COURT REVERSES THE TENTH CIRCUIT
The United States Supreme Court recently reviewed the Federal Rules of Civil Procedure and held that a voluntary dismissal qualifies as a final proceeding,
The Federal Rules of Civil Procedure (FRCP) provide a unified set of procedural standards for managing civil cases in federal courts, aiming to ensure proceedings are fair, efficient, and cost-effective, while maintaining consistency across the national federal court system.
In Waetzig v. Halliburton Energy Servs., Inc., 145 S. Ct. 690 (Feb. 256, 2025), an employee brought an age discrimination suit against his former employer but voluntarily dismissed the action without prejudice to pursue arbitration. After the arbitrator ruled against him, he returned to federal court, seeking to reopen his case under Rule 60.
Rule 60 of the FRCP allows a party to ask the court for relief from a judgment or order by demonstrating specific grounds such as mistake, inadvertence, or other qualifying reasons. This relief is only available after a “final judgment, order, or proceeding” has occurred.
The district court granted the plaintiff’s request under Rule 60 and reinstated the case. However, the Tenth Circuit Court of Appeals reversed, holding that a voluntary dismissal without prejudice was not a “final judgment, order, or proceeding,” since it did not require a court-issued judgment or order.
The United States Supreme Court granted certiorari to decide whether Rule 60(b) permits a court to reopen a case that was voluntarily dismissed without prejudice. The Supreme Court determined a voluntary dismissal is “final” because it “terminates the action itself.” Id. at 696. The Court also found that a voluntary dismissal constitutes a “proceeding” as that term was understood when Rule 60 was first adopted. The Court warned that a contrary interpretation would leave voluntarily dismissed cases in a procedural “no man’s land,” with no clear path for relief. Id. at 697.
Defendants should be mindful that plaintiffs may have the ability to request the reopening of a lawsuit under certain circumstances, including cases where the suit is initially dismissed voluntarily. This means defendants should be cautious about disposing of relevant documents or assuming that a voluntary dismissal fully resolves the matter.
You may read the decision in its entirety here: www.supremecourt.gov/opinions/24pdf/23-971_l6gn.pdf.