Summary
The United States District Court for the Eastern District of California denied Michael Witkin’s motion under Federal Rule of Civil Procedure 59(e) to alter or amend the judgment. The court held that the plaintiff had not shown a manifest error of law or fact and that his remaining arguments either expressed dissatisfaction with the prior order or repeated arguments that had been raised or could have been raised earlier.
Topics
Practice areas
Questions Presented
- Whether plaintiff demonstrated a manifest error of law or fact warranting relief under Federal Rule of Civil Procedure 59(e).
- Whether plaintiff's arguments concerning the alleged deprivation of outdoor exercise established that the court's prior qualified-immunity ruling was manifestly erroneous.
- Whether arguments previously raised, or arguments that could have been raised in the initial summary judgment motion, supported altering or amending the judgment.
Holdings
- Plaintiff failed to demonstrate that the court manifestly erred, or erred at all, in granting defendant qualified immunity; therefore, Rule 59(e) relief was unwarranted.
- Arguments that merely express dissatisfaction with the prior order, paraphrase arguments previously raised, or present arguments that could have been raised in the initial summary judgment motion do not warrant Rule 59(e) relief.
Key quotations
“Under Federal Rule of Civil Procedure 59(e), “amending a judgment after its entry [is] an extraordinary remedy which should be used sparingly.”” (at 1)
“The court held solely that defendant was entitled to qualified immunity because the “circumstances under which a temporary deprivation of outdoor exercise for an inmate not subject to continuous and long-term segregation or otherwise harsh conditions rises to the level of a [constitutional] violation” were not clearly established.” (at 2)
Factual background
Plaintiff, an inmate, challenged the alleged denial of constitutionally sufficient opportunities to exercise during a sixty-day period. The court previously granted defendant summary judgment based solely on qualified immunity, concluding that the constitutional right allegedly violated was not clearly established under the circumstances. Plaintiff's Rule 59(e) motion argued that the court had committed plain errors concerning whether the deprivation violated the Constitution.
Procedural history
The court rejected the magistrate judge's Findings and Recommendations, granted defendant's motion for summary judgment, denied plaintiff's motion for summary judgment, and ruled that defendant was entitled to qualified immunity. Plaintiff then moved to alter or amend the judgment under Rule 59(e), asserting errors of law and fact. The court denied the motion.