Bryson v. Union
- David Doty
- 0:25-cv-01717
- U.S. District Court · District of Minnesota
- 2
In Bryson v. Trans Union, Judge Doty denied plaintiff Brandon Bryson's motion to reconsider the dismissal of his case, finding no legal error or new evidence to justify reopening the judgment.
Individuals who have had federal lawsuits dismissed and are considering asking the court to reconsider the judgment; also relevant to anyone dealing with credit reporting or debt collection disputes in federal court.
What happened
In Bryson v. Trans Union, LLC and Transworld Systems, Inc., plaintiff Brandon Bryson asked the court to reverse or modify a prior judgment dismissing his case, arguing that he had drafted a new version of his complaint that would satisfy the court's pleading requirements.
Under Federal Rule of Civil Procedure 59(e), a party can ask the court to reconsider a final judgment, but only in narrow circumstances — specifically, to correct a clear legal or factual mistake, or to present evidence that was not previously available. The rule is not meant to give a losing party another chance to re-argue the same points or to present arguments they could have made earlier.
Judge David S. Doty denied Bryson's motion, finding that Bryson had shown no clear legal error in the court's dismissal and no newly discovered facts. The court noted that Bryson was essentially seeking a fourth opportunity to fix his complaint, which the court declined to allow.
The detailed version
- Bryson v. Union · No. 0:25-cv-01717
- David Doty
- Oct. 27, 2025
Background
Plaintiff Brandon Bryson brought suit against Trans Union, LLC and Transworld Systems, Inc. The opinion does not describe the underlying claims in detail, but it references prior dismissal of Bryson's case and indicates that Bryson had previously attempted to amend his complaint multiple times — the current proposed amendment would have been a third amended complaint, representing at least a fourth overall attempt to state a viable claim.
The Motion
Bryson filed a motion to alter or amend the judgment under Federal Rule of Civil Procedure 59(e). Rule 59(e) allows a party to ask the court to reconsider and modify a final judgment. Bryson's argument was that he had now drafted a third amended complaint that would meet the applicable pleading standards.
Legal Standard for Rule 59(e)
The court explained that a Rule 59(e) motion serves a limited purpose: it exists to correct a "manifest error of law or fact" or to present "newly discovered evidence." Citing Eighth Circuit precedent, the court emphasized three key limitations:
- The rule cannot be used to present evidence or arguments that could have been raised before judgment was entered. (Freeman v. Busch, 349 F.3d 582 (8th Cir. 2003))
- The rule cannot be used to rehash arguments already made and rejected. (Schoffstall v. Henderson, 223 F.3d 818 (8th Cir. 2000))
- The rule is not meant to routinely give litigants a second chance, but only to provide relief in "extraordinary circumstances." (Dale & Selby Superette & Deli v. U.S. Dep't of Ag., 838 F. Supp. 1346 (D. Minn. 1993))
The court also noted it has broad discretion in deciding whether to reopen a judgment under Rule 59(e).
Ruling
Judge Doty denied Bryson's motion. The court found that Bryson had not identified any manifest error of law or newly discovered facts in the prior dismissal. The court characterized the motion as seeking "a fourth bite at the apple," referring to the repeated attempts Bryson had already made to amend and re-plead his claims. The motion at ECF No. 45 was denied.
What the Opinion Does Not Address
The opinion does not describe the nature of Bryson's underlying claims against Trans Union, LLC or Transworld Systems, Inc., nor does it explain the specific reasons the prior complaint was dismissed. The procedural history before this motion is not detailed in this order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.