Ryne Mathias v. Jamie Baldwin

Summary

The court denies Jamie Baldwin’s motion for relief under Federal Rules of Civil Procedure 59(e) and 60(b) from an order remanding the case to the Confederated Salish and Kootenai Tribes Tribal Court. The court holds that the magistrate judge had authority to enter the remand order under 28 U.S.C. § 636(c), because the parties had consented to magistrate-judge jurisdiction. The court concludes that Baldwin failed to establish grounds for altering or vacating the remand order.

Holdings

1. When the parties consent to a magistrate judge's exercise of civil jurisdiction under 28 U.S.C. § 636(c), the limitations applicable to magistrate judges handling pretrial matters under § 636(b) do not apply, and the magistrate judge was authorized to issue the remand order.
2. The remand order was not void because the magistrate judge had authority to issue it under § 636(c); therefore, Baldwin was not entitled to relief under Rule 60(b)(4).
3. Baldwin did not demonstrate newly discovered evidence, clear error, an intervening change in controlling law, or other grounds warranting alteration or amendment of the remand order.

Questions Presented

1. Whether Baldwin was entitled to relief under Rule 59(e) from the order remanding the case to CSKT Tribal Court.
2. Whether the remand order was void under Rule 60(b)(4) because a magistrate judge allegedly lacked authority to enter it.
3. Whether a magistrate judge exercising civil jurisdiction under 28 U.S.C. § 636(c) may issue an order remanding a case for lack of subject-matter jurisdiction.

Disposition

other