Hazari v. County of Santa Clara

Background

On March 10, 2025, the court denied pro se plaintiff Cyrus Hazari’s administrative motion seeking relief by accommodation for disabilities. Hazari then filed a motion asking the court to set aside that order and reinstate the stay of the case. After a filing error, he refiled the motion. The court construed the filing as a motion for reconsideration of the March 10 order.

The earlier order had considered the parties’ papers, supporting documents, and Hazari’s medical information. The court had previously granted stay requests because the defendants did not oppose them, but it found no basis to continue the stay. It also found that the documented disabilities did not affect Hazari’s ability to prosecute the case, citing his rapid and lengthy filings.

Reconsideration standard

The court explained that it may reconsider an interlocutory order—an order entered before final judgment—but that reconsideration is disfavored. Under the applicable standards, reconsideration generally requires newly discovered evidence, clear error, an intervening change in controlling law, a material difference in fact or law that could not previously have been discovered through reasonable diligence, new material facts, a change in law, or a manifest failure to consider material facts or dispositive legal arguments. A party may not use reconsideration simply to repeat arguments previously presented or to raise arguments that could have been raised earlier.

Hazari’s arguments and the ruling

Hazari argued that the court had avoided important authorities cited in his writings and had failed to consider his medical information. The court reviewed the new medical information submitted with the reconsideration motions but found that it did not justify a stay. The court also found that Hazari had not identified any material change in fact or law warranting a stay and that his recent filings again showed his ability to prosecute the case.

Judge Beth Labson Freeman denied Hazari’s motion for reconsideration. The initial case-management conference remains scheduled for May 29, 2025, at 11:00 a.m. by Zoom, and Hazari must file his case-management statement by May 22, 2025.