Summary
The United States District Court for the Eastern District of Missouri denied Joseph Michael Devon Engel’s post-judgment motion seeking to reopen a closed prisoner civil-rights case, appoint counsel, and award damages. Construing the motion as arising under Federal Rule of Civil Procedure 60(b), the Court found no valid basis for relief. The Court also directed the Clerk to return any future documents filed in the closed matter unfiled based on Engel’s prior abusive litigation practices.
Topics
Practice areas
Questions Presented
- Whether Plaintiff's post-judgment motion, construed as a motion under Federal Rule of Civil Procedure 60(b), stated a valid basis for relief from the final judgment.
- Whether the court should direct the Clerk to return future documents submitted by Plaintiff in the closed matter unfiled based on his history of abusive litigation.
Holdings
- The motion did not set forth a valid basis for relief under any provision of Rule 60(b), so the court denied it.
- The court directed the Clerk to return any additional documents submitted by Plaintiff in the closed matter unfiled.
Key quotations
“Rule 60(b) allows a party to seek relief from a final judgment and reopen a case based on mistake or excusable neglect, newly discovered evidence, fraud, or the void or prospectively inequitable status of a judgment.”
“Rule 60(b) also includes a ‘catchall’ provision—Rule 60(b)(6)—that allows a district court to reopen a case for ‘any other reason that justifies relief.’”
Factual background
Plaintiff, a prisoner subject to 28 U.S.C. § 1915(g), sought to reopen the closed case and obtain counsel, damages, and other relief. He referenced prison grievances and alleged that he had been given an unnecessary tuberculosis shot, characterizing the treatment as intentional infliction of physical, mental, and emotional injuries. The court also relied on Plaintiff's prior pattern of abusive litigation in that court.
Procedural history
The case was dismissed on April 30, 2021. The Eighth Circuit dismissed Plaintiff's appeal on September 1, 2021. Plaintiff then filed the post-judgment motion at issue, which the district court denied and ordered the Clerk to return any future documents in the closed matter unfiled.