Jacob C. Long v. Blue Shield of California

Summary

The United States District Court for the District of Colorado denied Jacob C. Long’s motion to reopen his dismissed case under Federal Rule of Civil Procedure 60(b) and for leave to file an amended complaint under Rule 15(a)(2). The court held that plaintiff’s failure to bring ERISA claims or amend before judgment did not constitute excusable mistake and that the circumstances did not satisfy the extraordinary-relief standard under Rule 60(b)(6).

Holdings

1. A party's deliberate decision to assert preempted claims, or to refrain from amending after the preemption issue was raised, and the party's failure to predict the legal consequences of that decision do not constitute a mistake or excusable neglect warranting relief under Rule 60(b)(1).
2. A plaintiff seeking to reopen a case after final judgment to amend a complaint must satisfy the stringent Rule 60(b)(6) standard before the court considers leave to amend under Rule 15(a)(2); ordinary delay and a desire to pursue claims on the merits do not establish extraordinary circumstances or show that denying relief would offend justice.
3. The court need not decide whether plaintiff's proposed amendments would be futile after denying the motion to reopen the case.

Questions Presented

1. Whether plaintiff was entitled to relief from the final judgment under Federal Rule of Civil Procedure 60(b)(1) based on mistake or excusable neglect.
2. Whether plaintiff demonstrated the extraordinary circumstances required for relief under Rule 60(b)(6) to reopen the case and seek leave to amend his complaint.
3. Whether the court was required to consider the futility of plaintiff's proposed amendments.

Disposition

other