Seitz v. International Brotherhood of Teamsters

Background

James Edward Seitz sued the International Brotherhood of Teamsters, Teamsters Local 986, and several union representatives. He asserted claims including religious discrimination under Title VII and breach of the union’s duty to provide fair representation. The court previously granted the defendants’ motion to dismiss and entered judgment for them on September 3, 2024. Seitz timely appealed.

On August 21, 2025, an Equal Employment Opportunity Commission investigator issued a final determination that United Airlines had discriminated against a class of employees, including Seitz, by denying religious accommodations in violation of Title VII. Seitz then moved for relief from judgment under Federal Rule of Civil Procedure 60(b)(2), which concerns newly discovered evidence. Alternatively, he requested an indicative ruling under Rule 62.1 stating that the court would grant the motion, or consider granting it, if the appeals court sent the case back for that purpose.

The parties’ arguments

Because Seitz’s appeal was pending, the court stated that it lacked jurisdiction to decide the motion directly. Rule 62.1 nevertheless allowed the court to defer consideration, deny the motion, or state that it would grant the motion if the appeals court remanded the case for that purpose.

The defendants argued that the motion was filed after Rule 60(b)(2)’s one-year deadline, that Seitz had not properly supported the EEOC determination with an affidavit, that the determination did not contain newly discovered facts, that Seitz had not acted diligently, and that the determination would not change the outcome. Seitz argued that indicative rulings requested under Rule 60(b)(6) were not subject to a time limit, that he had supplemented the record with an affidavit, and that the EEOC determination was material because it showed that the defendants discriminated against him by adopting the employer’s policy.

Court’s reasoning

The court held that Seitz did not qualify for relief under Rule 60(b)(2) or Rule 60(b)(6). Rule 60(b)(2) requires a movant to show that the evidence is newly discovered, that he exercised due diligence to find it, and that the evidence likely would have changed the case’s outcome. Such a motion must be made no more than one year after entry of the judgment or order.

The court concluded that the EEOC determination did not change the result of its prior order. It explained that Seitz’s Title VII claim had been dismissed because an arbitration pursued by the union foreclosed that claim. The EEOC determination did not change that fact. The court also stated that Seitz filed the motion after the one-year deadline and therefore denied relief under Rule 60(b)(2).

The court rejected relief under Rule 60(b)(6), a general provision for exceptional reasons, because that provision cannot be used for circumstances covered by another Rule 60 provision. Seitz described his request as based on newly discovered evidence, so the court held that Rule 60(b)(2), rather than Rule 60(b)(6), governed.

Disposition

Judge Laurel Beeler denied the motion for relief from judgment and stated that the order resolved ECF No. 59.