State of Indiana v. Aaron Blocker

Summary

The United States District Court for the Northern District of Indiana denied Aaron Blocker’s motion under Federal Rule of Civil Procedure 59(e) to alter or amend its prior order remanding his attempted removal of state criminal proceedings. The court held that Blocker’s allegations did not satisfy the requirements for removal under 28 U.S.C. § 1443(1), and that the later dismissal of the state charges did not establish newly discovered evidence warranting relief. The opinion also reiterates the standards governing Rule 59(e) motions.

Holdings

1. Blocker did not demonstrate a manifest error of law because his motion largely reiterated arguments that had already been rejected and did not show wholesale disregard, misapplication, or failure to recognize controlling precedent.
2. The dismissal of the state criminal proceedings did not warrant alteration of the judgment because, once no state criminal prosecution existed, there was no state criminal prosecution to remove under 28 U.S.C. § 1443(1).
3. Blocker's allegations did not justify removal under § 1443(1): rights under laws providing equal civil rights are limited to rights specifically defined in terms of racial equality, and his equal-access claim did not satisfy the statute because he could not show that the right could not be enforced in state court.

Questions Presented

1. Whether Blocker demonstrated a manifest error of law or newly discovered evidence warranting alteration or amendment of the prior judgment under Federal Rule of Civil Procedure 59(e).
2. Whether dismissal of the state criminal proceedings supplied a basis to alter the prior determination that removal under 28 U.S.C. § 1443(1) was improper.

Disposition

dismissed