Staley v. Smart
- Figueredo
- 1:23-cv-03546
- U.S. District Court · Southern District of New York
- 2
In Staley v. Smart, Magistrate Judge Figueredo denied Staley’s request for an appellate-related ruling on Rule 60(b) relief because he offered no supporting facts.
Anthony T. Staley’s motion for an indicative ruling was denied; the order did not grant relief from the prior judgment or reopen the case.
What happened
Staley v. Smart involved Plaintiff Anthony T. Staley’s request for relief from a prior court order while his appeal was pending. The case had been closed after the court denied his motion for reconsideration, and Staley then appealed to the U.S. Court of Appeals for the Second Circuit.
Staley asked the district court to issue a ruling under Federal Rule of Civil Procedure 62.1 about his request for relief from judgment under Rule 60(b). He cited new evidence, constitutional violations, ongoing retaliation, equal-protection concerns, whistleblower retaliation, and judicial fairness, but he did not provide facts supporting those claims.
The court denied Staley’s motion because he did not show that any ground for relief under Rule 60(b) applied. Magistrate Judge Valerie Figueredo directed the Clerk of Court to terminate the motion from the docket.
The detailed version
- Staley v. Smart · No. 1:23-cv-03546
- Figueredo
- June 5, 2025
Background
On April 21, 2025, the court entered a final order denying Anthony T. Staley’s motion for reconsideration and closing the case. Staley filed a notice of appeal on May 5, 2025. While that appeal was pending, he filed a motion under Federal Rule of Civil Procedure 62.1 seeking an indicative ruling on a motion for relief from judgment under Rule 60(b).
Legal standards
Rule 62.1 allows a district court to address a motion affected by a pending appeal in several ways: it may defer consideration, deny the motion, or indicate that it would grant the motion or that the motion raises a substantial issue if the court of appeals sends the matter back. Rule 60(b) permits relief from an order or judgment for specified reasons, including mistake, newly discovered evidence, fraud or misconduct, a void judgment, satisfaction or reversal of the judgment, or another reason that justifies relief.
Court’s analysis
Staley identified what he described as new evidence, constitutional violations, ongoing retaliatory harm, unresolved factual issues, equal-protection concerns, whistleblower retaliation, and judicial-fairness issues. The court found that he provided no factual support for these allegations. It explained that a person seeking relief under Rule 60(b) must assert facts rather than make conclusory statements. The court also concluded that Staley had not shown that any Rule 60(b) ground applied, even under the more lenient standard used when reviewing filings by a person representing himself.
Disposition
The court denied Staley’s motion for an indicative ruling. It directed the Clerk of Court to terminate the motion at ECF No. 84. The order did not grant relief from judgment or otherwise reopen the case.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.