Baltas v. Chapdelaine

Summary

The United States District Court for the District of Connecticut denied six plaintiffs’ motion under Federal Rule of Civil Procedure 60(b)(6) to vacate summary judgment on their free exercise claims. The court held that their former counsel’s alleged inadequate representation constituted negligence or gross negligence, but not the constructive abandonment or extraordinary circumstances required for relief under Rule 60(b)(6).

Holdings

1. Negligence or even gross negligence by counsel, without constructive or actual abandonment of the client's case, does not constitute the exceptional circumstances required for relief under Rule 60(b)(6).
2. The moving plaintiffs did not demonstrate exceptional circumstances warranting relief from the prior summary judgment.

Questions Presented

1. Whether alleged negligence, gross negligence, inadequate investigation, and inadequate communication by former counsel constituted constructive abandonment and exceptional circumstances warranting relief from final judgment under Federal Rule of Civil Procedure 60(b)(6).
2. Whether the moving plaintiffs' declarations established that they had intended to pursue individualized free-exercise claims that prior counsel abandoned.

Disposition

other