Summary
The United States District Court for the Western District of Kentucky denied the plaintiffs’ Rule 59(e) motion to alter or amend judgment in litigation concerning the City of Oak Grove’s refusal to extend or connect water service to mobile-home communities. The court held that the plaintiffs identified no clear error, newly discovered evidence, intervening change in law, or manifest injustice, and that their arguments largely rehashed issues rejected on summary judgment.
Topics
Practice areas
Questions Presented
- Whether plaintiffs established a Rule 59(e) ground warranting alteration or vacation of the prior judgment.
- Whether alleged factual disputes concerning ownership of the water lines, testimony by Martin Nuss, statistical evidence, the City's stated code-based reason for denying service, or application of the 2020 Water Ordinance demonstrated clear error in the prior summary-judgment ruling.
- Whether plaintiffs could develop a Takings Clause theory for the first time in their Rule 59(e) motion.
Holdings
- The Court denied the Rule 59(e) motion because plaintiffs failed to establish clear error, newly discovered evidence, an intervening change in controlling law, or manifest injustice.
- The alleged disputes and evidentiary objections did not warrant reconsideration because, even assuming a factual dispute regarding ownership or pretext, the undisputed record still supported judgment for defendants on the federal claims.
- The Court declined to consider plaintiffs' newly developed Takings Clause argument because it could have been raised before judgment.
Key quotations
“Motions to alter or amend a judgment under Rule 59(e) “should only be granted if there was (1) a clear error of law; (2) newly discovered evidence; (3) an intervening change in controlling law; or (4) a need to prevent manifest injustice.”” (Order)
“The rule “allows for reconsideration” of a prior decision but “does not permit parties to effectively re-argue a case.”” (Order)
“Non-specific disagreement with a trial judge’s summary-judgment ruling, of course, is hardly a basis for granting reconsideration.” (Order)
Factual background
Plaintiffs challenged Oak Grove's refusal to provide water service for new mobile-home hookups, asserting federal constitutional and Fair Housing Act violations. The record included a dispute over ownership of water-distribution lines, testimony concerning the City's reasons for denying service, statistical evidence offered to support disparate impact, and a 2020 water ordinance governing connections and extensions. The Court concluded that the evidence did not establish FHA disparate treatment or disparate impact, that the City's decisions had a rational basis for equal-protection purposes, and that plaintiffs received adequate process.
Procedural history
Several mobile-home communities and a prospective resident sued the City of Oak Grove and its public-works director over the refusal to extend or connect water service to new mobile-home hookups. The Court previously granted defendants partial summary judgment on the federal claims and remanded the state statutory and equitable claims to state court. Plaintiffs then moved to alter the judgment under Rule 59(e), arguing that the summary-judgment ruling rested on factual and legal errors. The Court denied reconsideration.