Rodriguez-Morales v. Joseph
- Laura Swain
- 1:24-cv-09767
- U.S. District Court · Southern District of New York
- 4
In Rodriguez-Morales v. Joseph, Judge Swain denied motions seeking to undo the earlier dismissal of Rodriguez-Morales’s complaint.
Enki Rodriguez-Morales, whose requests to change, reconsider, or obtain relief from the judgment were denied; the prior dismissal and judgment were not disturbed by this order.
What happened
In Rodriguez-Morales v. Joseph, Enki Rodriguez-Morales filed an amended complaint after the court had dismissed his original complaint for failing to state a claim and allowed 30 days for an amendment. He filed the amended complaint after judgment had been entered, and he was representing himself.
The court treated the amended complaint as also asking to change the judgment, reconsider the earlier decision, or obtain relief from the judgment. The court found that Rodriguez-Morales had not shown that it overlooked controlling law or facts, and he had not shown grounds or extraordinary circumstances that would justify relief.
Judge Swain denied the motions under the federal rules and the local rule. The court directed the Clerk to terminate all motions and denied permission to appeal without paying filing fees, certifying that an appeal would not be taken in good faith.
The detailed version
- Rodriguez-Morales v. Joseph · No. 1:24-cv-09767
- Laura Swain
- Apr. 7, 2025
Background
Enki Rodriguez-Morales filed the action without a lawyer. On January 29, 2025, the court dismissed the complaint for failure to state a claim and gave him 30 days to file an amended complaint. He did not file one during that period, and the Clerk entered judgment on March 26, 2025. On April 3, 2025, Rodriguez-Morales filed an application to proceed without paying the filing fee and an amended complaint.
The court read the amended complaint broadly as also containing motions under three provisions: Federal Rule of Civil Procedure 59(e), which allows a party to ask the court to change or amend a judgment; Local Civil Rule 6.3, which allows reconsideration; and Federal Rule of Civil Procedure 60(b), which allows relief from a judgment or order in specified circumstances.
Rule 59(e) motion
The court said that a Rule 59(e) motion must show that the court overlooked controlling law or factual matters previously presented to it. The court also noted that such motions must be filed within 28 days after judgment. It found that Rodriguez-Morales had not shown that the court overlooked controlling decisions or factual matters concerning the dismissed action. The court therefore denied the Rule 59(e) motion.
Local Civil Rule 6.3 motion
The court explained that the standards under Rule 59(e) and Local Civil Rule 6.3 are the same. A motion under Local Civil Rule 6.3 must be filed within 14 days after the relevant determination or judgment. The court found that Rodriguez-Morales had not shown that it overlooked controlling law or facts concerning the dismissed action. The court therefore denied the motion under Local Civil Rule 6.3.
Rule 60(b) motion
Rule 60(b) permits relief from a judgment for specified reasons, including mistake, newly discovered evidence, misconduct by an opposing party, a void judgment, satisfaction or reversal of the judgment, or another reason justifying relief. The court found that Rodriguez-Morales had not shown that any of the first five grounds applied and denied relief under those provisions.
The court also denied relief under Rule 60(b)(6), the provision for other reasons justifying relief. It explained that this provision requires a reason different from those covered by the first five provisions, a filing within a reasonable time, and extraordinary circumstances. The court found that Rodriguez-Morales had not shown extraordinary circumstances warranting relief.
Disposition
The court denied the amended complaint, construed as including a motion for reconsideration. The Clerk was directed to terminate all motions in the action. The court also certified under 28 U.S.C. § 1915(a)(3) that any appeal from the order would not be taken in good faith and denied permission to appeal without paying filing fees.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.