Richard Mark Wagner v. Hon. Jessica Bierwerth, in her individual and official capacity as a judge of the Ramsey County Family Court, and Donald W. Harper, in his individual and official capacity as Court Administrator for the Ramsey County Family Court

Summary

The United States District Court for the District of Minnesota denied Richard Mark Wagner’s motion for relief from judgment under Federal Rule of Civil Procedure 60(b) and his motion for leave to amend under Rule 15(a)(2). The court held that Wagner did not establish grounds for Rule 60(b) relief and that his proposed Monell claims against Ramsey County were futile because they did not plausibly allege an unconstitutional policy or custom.

Holdings

1. Wagner was not entitled to relief from the judgment because his asserted mistake or excusable neglect concerned his failure to properly file post-judgment motions, not any mistake, inadvertence, surprise, or excusable neglect underlying the judgment itself, and he showed no exceptional circumstances warranting relief under Rule 60(b)(6).
2. After final judgment, a party may amend a pleading only with leave of court and only if the request is consistent with the stringent standards governing Rule 60(b) relief; the Rule 15(a)(2) liberal amendment standard does not independently permit amendment while the judgment remains in place.
3. Leave to amend was properly denied because the proposed amended complaint was futile and could not withstand a Rule 12(b)(6) motion.
4. Wagner did not plausibly allege that Ramsey County maintained an unconstitutional official policy.
5. Wagner did not plausibly allege an unconstitutional municipal custom because his proposed complaint identified only a single alleged act.

Questions Presented

1. Whether Wagner established grounds under Federal Rule of Civil Procedure 60(b)(1) or 60(b)(6) for relief from the judgment dismissing his complaint.
2. Whether Wagner could amend his complaint after final judgment without first obtaining relief from the judgment.
3. Whether the proposed amended complaint plausibly alleged a municipal policy or custom sufficient to support a Monell claim under 42 U.S.C. § 1983.
4. Whether the proposed amendment was futile because it could not withstand a motion to dismiss under Rule 12(b)(6).

Disposition

other