Gregory Scott Holt v. Potlatch No. 1 Financial Credit Union (P1FCU)

Summary

The United States District Court for the District of Idaho denied Gregory Scott Holt’s motions for reconsideration, a protective order, to quash, and exemption from PACER fees. The court also denied Potlatch No. 1 Financial Credit Union’s motion for attorney’s fees because the case had been dismissed for lack of subject-matter jurisdiction and no independent jurisdictional basis supported an award of fees. The decision was entered as a memorandum decision and order on March 24, 2026.

Holdings

1. A Rule 59(e) motion may not be used to relitigate matters or raise arguments or evidence that could have been presented before judgment; Holt failed to identify qualifying grounds for reconsideration.
2. A motion for a protective order is unavailable where the action is no longer pending and the motion does not concern discovery or satisfy Rule 26(c)'s meet-and-confer certification requirement.
3. The motion to quash was properly denied as moot because denial of the protective-order motion did not depend on P1FCU's response.
4. A district court that lacked subject matter jurisdiction over the underlying action may not award attorney's fees absent an independent jurisdictional basis, such as a sanctions motion under Federal Rule of Civil Procedure 11.

Questions Presented

1. Whether Holt established grounds under Federal Rule of Civil Procedure 59(e) for reconsideration of the dismissal order.
2. Whether Holt was entitled to a protective order under Federal Rule of Civil Procedure 26(c).
3. Whether Holt's motion to quash P1FCU's response should be granted.
4. Whether Holt was entitled to an exemption from PACER fees.
5. Whether the court had jurisdictional authority to award P1FCU attorney's fees after dismissing the action for lack of subject matter jurisdiction.

Disposition

other