Khan v. SAP Labs, LLC

Summary

The United States District Court for the Northern District of California denied Muhammad Khan’s motion to alter or amend the judgment under Federal Rule of Civil Procedure 59(e) and for relief from judgment under Rule 60(b). The court held that Khan’s motion was timely under the prisoner mailbox rule but failed to establish clear error, newly discovered evidence, an intervening change in law, or extraordinary circumstances. The court also accepted SAP’s late opposition because of confusion caused by the docketed response deadline.

Holdings

1. A prisoner's Rule 59(e) motion is deemed filed when delivered to prison authorities for forwarding, and Khan's motion was timely under that mailbox rule because the record showed delivery within 28 days after entry of judgment.
2. Khan was not entitled to relief under Rule 59(e) because he identified no newly discovered evidence, intervening change in controlling law, or clear error.
3. The court exercised its discretion to consider SAP's untimely opposition because a docketing error created confusion about the response deadline.
4. Khan was not entitled to relief from judgment under Rule 60(b)(6) because he failed to demonstrate extraordinary circumstances justifying relief.

Questions Presented

1. Whether Khan's motion to alter or amend the August 30, 2022 judgment was timely under Rule 59(e), including under the prisoner mailbox rule.
2. Whether Khan established newly discovered evidence, clear error, or an intervening change in controlling law warranting relief under Rule 59(e).
3. Whether the court should exercise discretion to consider SAP's untimely opposition to the Rule 59(e) motion.
4. Whether Khan demonstrated extraordinary circumstances warranting relief from judgment under Rule 60(b)(6).

Disposition

other