Sanai v. Cardona

Background

Cyrus Sanai brought this action seeking declaratory and injunctive relief against George Cardona, identified as the State Bar Chief Trial Counsel, and Leah Wilson, identified as the State Bar Executive Director. Sanai filed the action after receiving a letter notifying him that the State Bar would initiate disciplinary proceedings against him.

Sanai filed a second amended complaint. The defendants then moved to dismiss. On July 16, 2024, the court granted that motion and held that Younger abstention required dismissal of Sanai’s claims. Younger abstention is a rule under which a federal court generally avoids interfering with certain ongoing state proceedings.

Motion for Reconsideration

Sanai moved for reconsideration under Federal Rule of Civil Procedure 59(e) or Rule 60(b). Rule 59(e) permits a party to ask the court to alter or amend a judgment, while Rule 60(b) permits relief from a final judgment for specified reasons, including mistake, newly discovered evidence, fraud, a void judgment, satisfaction of the judgment, or another reason justifying relief.

Sanai argued that the court mistakenly granted the defendants’ motion to dismiss and that new facts justified relief. The court explained that dissatisfaction with its decision or a belief that the court was wrong is not enough. A qualifying mistake could include an excusable mistake by a party or lawyer or a substantive legal or factual error by the court. The court also considered Sanai’s evidence that another discovery request had been denied in his disciplinary proceedings.

Ruling

The court denied Sanai’s motion for reconsideration. It concluded that Sanai disagreed with the prior dismissal but did not identify a substantive mistake in that ruling. It also concluded that the evidence concerning the denial of discovery did not change the court’s analysis. The order therefore left the earlier dismissal in place.

Disposition

Sanai’s motion for reconsideration was denied.