Partridge v. Black Rock LLC

Background

Nicholas Partridge filed the action without a lawyer. On August 25, 2025, the Court dismissed his amended complaint for failure to state a claim on which relief could be granted. The Clerk entered judgment on August 26, 2025, and Partridge filed a notice of appeal the same day. On September 7, 2025, Partridge filed a letter stating that he owned Cash Harbor LLC and asking that claims brought on behalf of Cash Harbor LLC be allowed to proceed.

The earlier dismissal stated that claims brought on behalf of Cash Harbor LLC were dismissed without prejudice to those claims being brought by Cash Harbor LLC through a lawyer. In the present order, the Court treated Partridge’s letter as a motion under Federal Rule of Civil Procedure 59(e) to alter or amend the judgment, a motion for reconsideration under Local Civil Rule 6.3, and a motion for relief from a judgment or order under Federal Rule of Civil Procedure 60(b).

Jurisdiction to Consider the Motion

Because Partridge had filed a notice of appeal, the Court first addressed whether it still had authority to consider the requested relief. The Court explained that a notice of appeal generally transfers control over the appealed aspects of a case to the Court of Appeals. But the appellate rules allow the district court to decide a timely Rule 59 or Rule 60 motion filed within 28 days after judgment. Partridge filed his letter within that period, so the Court concluded that it had authority to consider the motion.

Rule 59(e) Motion

A Rule 59(e) motion asks the court to alter or amend a judgment. The moving party must show that the court overlooked controlling law or factual matters that had already been presented. The Court concluded that Partridge had not made that showing.

Partridge argued that claims brought for Cash Harbor LLC should proceed because he owned the limited liability company. The Court stated that even a solely owned or single-member limited liability company cannot appear in federal court without an attorney. Because Partridge was not an attorney, the Court held that he could not bring claims for Cash Harbor LLC. The Court therefore denied the Rule 59(e) motion.

Local Civil Rule 6.3 Motion

The Court stated that Local Civil Rule 6.3 uses the same standard as Rule 59(e): the party seeking reconsideration must show that the Court overlooked controlling law or facts previously presented. Because Partridge had not made that showing concerning the dismissed action, the Court denied his 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, fraud or misconduct, a void judgment, satisfaction or reversal of an earlier judgment, or another reason justifying relief. The Court concluded that Partridge had not shown that any of the first five categories applied. It therefore denied relief under those provisions.

The Court also considered Rule 60(b)(6), which covers other reasons justifying relief. Such a motion must rely on a reason different from those covered by the first five categories and must show both a reasonable filing time and extraordinary circumstances. The Court concluded that Partridge had not shown extraordinary circumstances and denied relief under Rule 60(b)(6) as well.

Disposition

The Court denied Partridge’s motion for reconsideration. It directed the Clerk of Court to terminate all motions in the action. The Court also certified under 28 U.S.C. § 1915(a)(3) that an appeal from this order would not be taken in good faith and denied permission to appeal without paying filing fees.