Manchanda v. Attorney Grievance Committee 1st Department

Background

Rahul Dev Manchanda filed the action without a lawyer. The court had dismissed his complaint on May 16, 2025, without prejudice, under 28 U.S.C. § 1651 because he had not complied with an injunction issued in a prior related proceeding. On the same day, Manchanda filed a document titled a “notice of motion for contempt of court against Judge T Swain and Assistant Attorney General Anjali Bhat.” He sought sanctions against the judge and to “restore” the case.

The court treated the filing as a motion to alter or amend the judgment under Federal Rule of Civil Procedure 59(e), a motion for reconsideration under Local Civil Rule 6.3, and a motion for relief from the judgment under Rule 60(b). Although filings by people without lawyers are generally read liberally, the court noted that Manchanda is an attorney representing himself and therefore is not ordinarily entitled to the special consideration given to other self-represented litigants.

Recusal

Because Manchanda sought sanctions against Judge Swain, the court first considered whether she had to recuse herself. It concluded that recusal was not warranted. The court found that Manchanda stated no facts showing deep-seated favoritism or antagonism that would make fair judgment impossible. It explained that dissatisfaction with judicial rulings generally provides a basis for appeal, not recusal.

Rule 59(e) motion

The court denied relief under Rule 59(e). That rule allows a party to seek alteration or amendment of a judgment, but the party must show that the court overlooked controlling law or factual matters previously presented. The court found that Manchanda had not made that showing concerning the dismissal.

Local Civil Rule 6.3 motion

The court also denied reconsideration under Local Civil Rule 6.3. It applied the same standard as under Rule 59(e) and again found that Manchanda had not shown that the court overlooked controlling law or factual matters.

Rule 60(b) motion

Rule 60(b) permits relief from an order or judgment for specified reasons, including mistake, newly discovered evidence, opposing-party misconduct, a void judgment, satisfaction or reversal of the judgment, or other extraordinary circumstances. The court denied relief under the first five parts of the rule because Manchanda had not shown that any applied.

The court also denied relief under Rule 60(b)(6), the provision covering other reasons that might justify relief. It found that Manchanda had not identified extraordinary circumstances warranting reconsideration of the dismissal. The court noted that the action had been dismissed for failure to comply with the requirements imposed in a prior related proceeding and that his motion did not state facts supporting relief.

Disposition

Judge Swain denied Manchanda's motion, as construed as a motion for reconsideration. The clerk was directed to terminate all motions, and the case remains closed. The court certified under 28 U.S.C. § 1915(a)(3) that any appeal would not be taken in good faith and denied permission to proceed without paying filing fees for purposes of an appeal.