Jaiyeola v. Apple, Inc
- Edward Davila
- 5:23-cv-03462
- U.S. District Court · Northern District of California
- 7
In Jaiyeola v. Apple, Inc., Judge Davila denied two motions to undo earlier orders, leaving the case closed.
Jaiyeola’s requests to undo the dismissal and disqualification orders were denied, and Apple remains the defendant in a case that remains closed.
What happened
In Jaiyeola v. Apple, Inc., the court had previously dismissed Jaiyeola’s claims against Apple and closed the case. Jaiyeola then asked the court to undo that dismissal and a later order denying his request to disqualify the judge.
Jaiyeola argued that the dismissal order contained legal and factual errors, violated his rights as a self-represented litigant, and relied on a witness’s allegedly false declaration. He also repeated arguments from his earlier request to disqualify the judge. The court separately denied his request to take notice of orders from two other cases.
Judge Edward J. Davila denied both motions under the federal rule governing relief from final orders. The court said the arguments did not establish a valid reason to undo either order, and that it had not relied on the challenged declaration. The case remains closed.
The detailed version
- Jaiyeola v. Apple, Inc · No. 5:23-cv-03462
- Edward Davila
- Jan. 30, 2025
Background
The court had previously granted Apple’s motion to dismiss under Federal Rule of Civil Procedure 12(b)(6), which permits dismissal when a complaint does not adequately state a legal claim. The court also denied Jaiyeola’s motion for leave to file a proposed second amended complaint, closed the case, and entered judgment.
Jaiyeola later filed one motion seeking relief from the dismissal order and another seeking relief from the order denying his motion to disqualify the judge. The court considered both motions under Rule 60(b), which allows a court to provide relief from a final judgment or order for specified reasons, including mistake, newly discovered evidence, fraud, a void judgment, or extraordinary circumstances.
Judicial-Notice Request
Jaiyeola asked the court to take judicial notice of orders from two other cases. Judicial notice allows a court to accept certain facts that are not reasonably disputable. The court denied the request because the other orders had not been introduced into this case and the exceptions for related litigation or matters incorporated into the pleadings did not apply.
Motion to Vacate the Dismissal Order
Jaiyeola sought relief under Rules 60(b)(1), 60(b)(4), and 60(b)(6).
Under Rule 60(b)(1), Jaiyeola argued that the court should have applied the McDonnell Douglas framework to his Title VII claims, improperly acted as a fact-finder, ignored facts in exhibits, and denied leave to amend based on futility without a motion requesting leave. The court rejected these arguments. It explained that the McDonnell Douglas framework is an evidentiary framework, not a pleading standard; that the challenged references to evidence appeared in the procedural history rather than as factual findings supporting dismissal; and that the exhibits did not establish that Jaiyeola had adequately stated a plausible claim. The court also stated that it had expressly resolved Jaiyeola’s motion for leave to file the proposed amended complaint and could deny amendment when amendment would be futile. The court denied relief under Rule 60(b)(1).
Under Rule 60(b)(4), Jaiyeola argued that the judgment was void because the court failed to interpret his pleadings generously as a self-represented litigant and made improper conclusions when comparing his complaints. The court said these arguments were not proper grounds for treating the judgment as void. It stated that it had given Jaiyeola procedural leniency, while explaining that self-represented pleadings still must give a defendant notice of what it allegedly did wrong and why the plaintiff is entitled to relief. The court also stated that it could compare a proposed amendment with the existing complaint to decide whether amendment would be futile. The court denied relief under Rule 60(b)(4).
Under Rule 60(b)(6), Jaiyeola argued that Apple witness Sowmya Laxminarayanan committed perjury in a declaration attached to Apple’s motion. The court did not decide whether that allegation was true because it had not relied on the declaration in dismissing the case. Jaiyeola also challenged the court’s use of a stamped order in denying an earlier motion concerning preliminary injunctive relief. The court found that argument was not a proper basis for relief and was irrelevant to the dismissal order. The court denied relief under Rule 60(b)(6).
Motion to Vacate the Disqualification Order
Jaiyeola’s second motion sought to vacate the order denying his motion to disqualify the judge. Although he cited Rules 60(b)(1) and 60(b)(4), the court found that he did not present arguments showing mistake, inadvertence, surprise, excusable neglect, or a void order. Instead, he repeated arguments from his original disqualification motion and disputed the court’s conclusions. The court held that those arguments were not grounds for relief under Rule 60(b) and denied the motion under Rules 60(b)(1) and 60(b)(4).
Jaiyeola also requested sanctions against Apple based on Apple’s opposition to the motion. The court found Apple’s opposition appropriate and declined to impose sanctions.
Disposition
The court denied Jaiyeola’s motions to vacate the dismissal order and the disqualification order. The case remains closed.
Read the full 7-page opinion on CourtListener, the free public archive maintained by the Free Law Project.