Austin v. Tesla Motors, Inc.

Background

George Jarvis Austin moved for a new trial, correction of the court’s judgment and dispositive order, and appointment of a new judge. The motions were docketed as 303 and 304 and were materially identical. Tesla Motors, Inc. did not oppose the motions. The court decided them without a hearing.

Austin had set hearings before the court’s Executive Committee and another judge without authorization. The court stated that motions must be directed to the judge assigned to the case. It denied Austin’s request to have a matter heard by the Executive Committee and stated that it would not refer any matter to another judge.

Austin had previously moved for a mistrial and for the undersigned judge’s recusal or disqualification. The court had denied those motions earlier and found no legal or factual basis to revisit that decision.

Rules 59 and 60 requests

Austin did not identify specific grounds under Federal Rules of Civil Procedure 59 or 60. Because there had been no trial, the court held that he was not entitled to a new trial. It construed his request to correct the judgment as a Rule 59(e) motion to alter or amend the judgment and also as a Rule 60(b)(1) motion based on alleged judicial error.

Rule 59(e) permits a court to alter or amend a judgment in limited circumstances, such as newly discovered evidence, clear error, or an intervening change in controlling law. Rule 60(b)(1) permits relief from a final judgment or order for mistake, inadvertence, surprise, or excusable neglect. The court described relief under both rules as extraordinary and discretionary.

Austin argued that his pleadings alleged new harms by Tesla that had not previously been pleaded, and that the court therefore erred when it ruled that his claims were barred by claim preclusion, also called res judicata, and granted summary judgment. The court found that Austin had made the same argument in opposing summary judgment. It had previously considered and rejected his allegations, finding that they concerned alleged wrongs connected with his work at Tesla from 2019 to 2020.

The court held that Rule 59(e) cannot be used to relitigate matters already decided. It denied the Rule 59(e) motion and denied the Rule 60(b)(1) motion on the same grounds, explaining that Rule 60 does not permit a party to reargue issues the court previously decided.

Disposition

The court denied all relief and terminated docket entries 303 and 304. It admonished Austin against filing additional duplicative motions in the closed case and stated that filings must comply with the Federal Rules of Civil Procedure and the district’s local rules. The court warned that other filings or continued excessive or duplicative filings could result in termination of Austin’s electronic filing privileges.