Rev. Heidi Grossman Lepp v. Conrad Mallett, Jr., et al.

Summary

The United States District Court for the Eastern District of Michigan denies pro se plaintiff Heidi Grossman Lepp’s motion for relief from judgment under Federal Rule of Civil Procedure 60(b). The court holds that plaintiff did not establish an error of law, newly discovered evidence, or extraordinary circumstances warranting relief, and concludes that her objections to the magistrate judge’s report and recommendation and order denying leave to amend would not change the outcome. The court also declines to consider materials submitted as a declaration and an AI-generated legal analysis.

Holdings

1. Plaintiff did not establish that the court made a substantive error of law or fact in applying standing doctrine; repeating previously considered allegations and disputing the court's treatment of precedent did not justify relief from judgment.
2. Plaintiff demonstrated an excusable mistake in failing to timely file objections, but relief was denied because the objections would not have changed the outcome.
3. Plaintiff was not entitled to relief under Rule 60(b)(2) because the cited judicial decisions and later events were not newly discovered, material, controlling evidence fairly traceable to the defendant's conduct.
4. Plaintiff failed to establish extraordinary circumstances warranting Rule 60(b)(6) relief, and she could not bypass that requirement by combining Rule 60(b)(6) with Rule 15(a)'s liberal amendment standard.

Questions Presented

1. Whether Plaintiff established grounds under Rule 60(b)(1) based on a judicial error of law or excusable neglect.
2. Whether Plaintiff's untimely objections to the report and recommendation and the magistrate judge's order warranted relief from judgment.
3. Whether decisions from another district and later events constituted newly discovered evidence under Rule 60(b)(2).
4. Whether extraordinary circumstances justified relief under Rule 60(b)(6), including reopening the case to permit amendment.
5. Whether Plaintiff's standing allegations established an error in the prior dismissal.

Disposition

other