Jeter v. Wiley
- Loretta Preska
- 1:14-cv-02724
- U.S. District Court · Southern District of New York
- 8
In Jeter v. Wiley, Judge Preska denied Sharon Jeter’s motions seeking to reopen about a dozen closed cases.
Sharon Jeter, whose motions to reopen the listed closed cases were denied, and the defendants in those cases, whose prior case closures remain in place.
What happened
Jeter v. Wiley involved Sharon Jeter’s requests to reopen about a dozen cases that she filed in 2014 and 2015 and that had been closed. Jeter represented herself, and the court treated her filings as requests for relief from earlier judgments or orders rather than requests for emergency court orders.
Jeter filed the requests about ten years after the cases were closed. She challenged the closures, complained that she had not received discovery or been allowed to testify, and alleged that defendants had evidence connected to crimes and torts against her, the United States, and Israel.
Judge Loretta A. Preska denied the motions. She ruled that the requests were too late under some parts of the governing rule, did not show that the judgments were invalid or had been satisfied, and were not filed within a reasonable time or supported by extraordinary circumstances. She also directed the Clerk to close the motions and denied permission to appeal without paying filing fees.
The detailed version
- Jeter v. Wiley · No. 1:14-cv-02724
- Loretta Preska
- Mar. 11, 2025
Background
Sharon Jeter, proceeding without a lawyer, filed the cases listed in the order in 2014 and 2015. The opinion states that many were dismissed without prejudice on procedural grounds, including failure to submit an application to proceed without paying filing fees or failure to sign a complaint. Some cases were dismissed because Jeter had filed them as a prisoner while barred by 28 U.S.C. § 1915(g) from proceeding without paying filing fees.
About a decade after the cases were closed, Jeter filed substantially identical submissions in those cases. Although styled as proposed orders seeking an emergency injunction or temporary restraining order, the submissions challenged how the earlier cases had been resolved. The court therefore treated them as motions under Rule 60(b) of the Federal Rules of Civil Procedure, which permits a party to seek relief from a judgment or order in specified circumstances.
Arguments and analysis
Rule 60(b)(1), (2), and (3) cover mistake or excusable neglect, newly discovered evidence, and fraud or misconduct. Motions under those provisions must be filed no more than one year after the judgment or order. Because Jeter filed her motions approximately ten years after the judgments, the court held that they were untimely to the extent they relied on those provisions.
The court also found that Jeter had not shown that the judgments were void under Rule 60(b)(4), or that they had been satisfied, released, discharged, reversed, or vacated under Rule 60(b)(5). Jeter challenged the fact that her cases remained closed without being heard and complained that she had not received discovery. She also alleged that defendants had evidence they stole or used to commit crimes and torts, and complained that defendants stopped her days in court and prevented her from testifying before or learning about a grand jury. The court concluded that these arguments did not establish grounds for relief under Rule 60(b)(4) or (5).
Rule 60(b)(6) allows relief for another reason that justifies it, but only when the reason is different from those covered by provisions (1) through (5). The court held that Jeter’s motions were not filed within a reasonable time and did not demonstrate extraordinary circumstances. It therefore denied relief under that provision as well.
Disposition
The court denied Jeter’s Rule 60(b) motions. It characterized the motions as lacking any legally recognized basis for relief and as frivolous. The court cautioned that continued filing of frivolous and burdensome motions in closed cases could lead to an order directing the Clerk not to accept additional filings in those cases.
Judge Loretta A. Preska directed the Clerk to close the specified motions in the twelve listed case dockets. The court also certified under 28 U.S.C. § 1915(a)(3) that any appeal would not be taken in good faith and denied Jeter permission to appeal without paying filing fees.
Read the full 8-page opinion on CourtListener, the free public archive maintained by the Free Law Project.