- Court: United States Supreme Court
- Area(s) of Law: Civil Procedure
- Date Filed: June 13, 2022
- Case #: No. 21-5726
- Judge(s)/Court Below: THOMAS, J., delivered the opinion of the Court, in which ROBERTS, C. J., and BREYER, ALITO, SOTOMAYOR, KAGAN, KAVANAUGH, and BARRETT, JJ., joined. SOTOMAYOR, J., filed a concurring opinion. GORSUCH, J., filed a dissenting opinion.
- Full Text Opinion
Petitioner was convicted of various crimes alongside seven codefendants. Petitioner filed a motion to reopen proceedings based on a mistake under Federal Rule of Civil Procedure 60(b), and it was denied as untimely because it was more than one year after his conviction became final. Petitioner argues the Rule 60(b)(1) 1-year limitation applies only to “mistakes” that are factual errors made by someone other than a judge, and that judicial errors of law are another “reason that justifies relief” under Rule 60(b)(6), meaning his motion was not subject to a time limitation. The District Court for the Southern District of Florida rejected this argument, and the Eleventh Circuit affirmed. The Supreme Court determined that as a matter of text, structure, and history, the term “mistake” includes a judge’s legal errors. They determined that had the term “mistake” been intended to exclude these errors, the drafters could have easily drafted language to that effect. Because Petitioner’s Rule 60(b) motion alleged a legal error by a judge, it was subject to the Rule 60(b)(1) 1-year limitation and therefore was untimely filed. The Eleventh Circuit’s judgment was affirmed.