Banker v. Driscoll

Summary

The United States District Court for the District of Columbia denied George Banker’s motion to alter or amend judgment under Federal Rule of Civil Procedure 59(e) and dismissed as moot his motion for leave to file a second amended complaint under Rule 15(a)(2). The court held that Banker had not shown clear error, newly available evidence, or manifest injustice, and that postjudgment amendment was unavailable after denial of Rule 59(e) relief.

Holdings

1. Rule 59(e) relief is not warranted where the movant merely repeats arguments previously rejected or disagrees with the court's prior ruling, and Banker did not show that the prior dismissal was clearly erroneous.
2. The possible expiration of applicable statutes of limitations, standing alone, did not establish the manifest injustice necessary for extraordinary Rule 59(e) relief.
3. A postjudgment motion to amend becomes moot when the court denies the accompanying Rule 59(e) motion because the plaintiff must first satisfy the more stringent standard for reopening the judgment.

Questions Presented

1. Whether Banker established a basis under Rule 59(e) to alter or amend the judgment dismissing his discrimination claims.
2. Whether the potential expiration of the Title VII and ADEA limitations periods created manifest injustice warranting Rule 59(e) relief.
3. Whether the Court could grant leave to file a second amended complaint after judgment when Banker had not first satisfied Rule 59(e)'s standard for reopening the judgment.

Disposition

other