Walker v. Krol

Background

Jeffrey E. Walker filed this civil-rights action under 42 U.S.C. § 1983 in December 2015. The court dismissed the action with prejudice on August 7, 2017, for failure to prosecute after Walker repeatedly refused to participate in depositions, did not oppose the defendants’ dismissal motion, and did not respond to an order requiring him to explain why the case should not be dismissed.

Walker later asked the court to set aside the judgment under Federal Rule of Civil Procedure 60(b)(6), which permits relief from a final judgment in extraordinary circumstances. The court denied his first request in July 2022. In his renewed request, Walker argued that involuntary psychiatric medication, mental-health problems, other litigation, prison conditions, and physical-health limitations prevented him from timely pursuing this case.

Other Requests

The defendants asked to file under seal medical and psychiatric records and portions of their supplemental briefing that discussed those records. The court found that protecting medical privacy was a compelling reason for sealing and that the request was narrowly limited to the records and related references. The court granted the request. The sealed portions were to remain sealed through the end of the case and any appellate proceedings.

The defendants also asked the court to take judicial notice of pleadings filed by Walker in another federal case. Judicial notice allows a court to recognize facts that are not reasonably disputed, such as the existence of court filings. The court granted the request only to recognize that Walker filed the specified pleadings; it did not accept the truth of the statements made in those filings.

Rule 60(b)(6) Analysis

The court applied the factors relevant to Rule 60(b)(6) relief, including whether extraordinary circumstances existed, whether Walker acted diligently, the interest in finality, the delay between the judgment and the motion, and the connection between the claimed extraordinary circumstances and the requested relief.

The court assumed, for purposes of its analysis, that Walker may have lacked the capacity to pursue litigation from November 2016 to July 2020. It nevertheless found that he did not show extraordinary circumstances after his medication was reduced in 2020. From August 2020 through March 2021, Walker pursued several other legal matters, including another federal civil-rights case, petitions concerning arrest records, and a state petition for a writ challenging his conviction. Medical records also described him as alert, oriented, coherent, and heavily engaged in legal work during the relevant period.

The court found that Walker’s explanations for delaying his request to reopen were contradicted by the record or were not circumstances beyond his control. It also found that he waited until January 2022 to seek reopening even though he had been actively litigating other matters. The court further concluded that the case’s closure nearly five years earlier and the likely fading of witnesses’ memories weighed against reopening.

Disposition

The court granted the defendants’ request to file certain portions of their supplemental briefing under seal and granted their request for judicial notice. It denied Walker’s request for counsel as moot and denied his motion to vacate the judgment under Rule 60(b)(6). The case remains closed.