Revels v. Holly

Background

Tyler Revels filed this pro se civil-rights action under 42 U.S.C. § 1983. He alleged that, while detained at Santa Rita Jail in 2023, jail officials Tichia Holly and Gary Dean White violated his First Amendment right to practice his religion by denying him four video visits over six days because he wore religious headwear.

The court initially dismissed the case after Revels did not provide an updated address as required by a local court rule. The court later reopened the action at Revels’s request. The court also acknowledged that its staff had entered an incorrect state and mailbox information for Revels’s address and later corrected the address based on information in the record.

Defendants moved for summary judgment, a procedure for deciding a case when the record shows no genuine factual dispute requiring a trial. Revels filed an opposition. On September 29, 2025, the court granted summary judgment for defendants, finding, among other things, that Revels had not shown a triable issue of fact about whether defendants substantially burdened his religious practice.

Motion for Reconsideration

Revels submitted a document titled “Motion for Reconsideration.” The motion did not identify the order he wanted reconsidered, so the court presumed he was challenging the order granting summary judgment. Revels argued that defendants had served documents at an incorrect address despite knowing his correct address. He also requested a copy of the docket sheet so he could seek earlier filings that may have been sent to the wrong address.

The defendants argued that Revels had not met the standard for reconsidering the summary-judgment order under Federal Rule of Civil Procedure 59(e). They pointed out that Revels had received the summary-judgment motion, as shown by his detailed opposition, and argued that the record did not show he failed to receive the other documents mailed to the address defendants used.

Court’s Analysis

The court explained that Rule 59(e) permits reconsideration of a final judgment or order on four basic grounds: a serious legal or factual error underlying the judgment, newly discovered or previously unavailable evidence, serious unfairness, or an intervening change in controlling law. The court described changing a judgment after its entry as an extraordinary remedy that should be used sparingly.

The court held that Revels had not argued or demonstrated that any of those grounds applied. It concluded that defendants’ mistake in mailing documents to P.O. Box 6000 instead of P.O. Box 7000 did not amount to serious unfairness because Revels appeared to have received the documents. In particular, his detailed opposition showed that he received the summary-judgment motion. The court found nothing in the record supporting reconsideration of the order granting summary judgment.

Disposition

The court DENIED Revels’s motion for reconsideration. The case remains closed. The Clerk was directed to send Revels a courtesy copy of the docket sheet, and the order terminated ECF No. 35.