Jiang v. KNTV Television LLC

Background

Baiting Jiang filed this action in 2021. On December 23, 2025, Magistrate Judge Laurel Beeler issued a report and recommendation recommending dismissal. No objections were filed within the following three weeks. On January 15, 2026, the court adopted the recommendation, dismissed the case, and entered judgment for the defendants.

Jiang later moved under Federal Rules of Civil Procedure 59(e) and 60(b) to alter or amend the judgment or obtain relief from it. She sought to vacate the judgment so she could file late objections to the report and recommendation.

Motion to Alter or Amend Judgment

Rule 59(e) permits a court to alter or amend a judgment in circumstances including newly discovered evidence, clear error or manifest injustice, or an intervening change in controlling law. Rule 60(b) permits relief from a final judgment for specified reasons, including mistake, excusable neglect, newly discovered evidence, fraud, misrepresentation, misconduct, or another reason justifying relief. The court described relief under either rule as an extraordinary remedy that should be used sparingly.

Jiang asserted that health conditions affecting her and her mother limited her ability to keep up with litigation deadlines. She also said a computer virus prevented her from receiving relevant electronic docket notices.

The court found that Jiang electronically filed three documents on January 6, 2026, the date objections were due. The court reasoned that she would have had to access the docket to file those documents, and that the report and recommendation would have appeared there in bold text. The filings included a complaint with numerous exhibits, a proposed summons, and a civil cover sheet. The court concluded that these filings showed Jiang was able to conduct substantial litigation activity at that time. It also noted that she did not explain why she could complete those tasks but could not file objections or research the relevant facts, and that she waited more than three weeks after the January 6 filings before seeking relief.

The court held that Jiang had not shown that she was entitled to the extraordinary remedy requested. It DENIED the Motion to Alter Judgment.

Motions to Seal

The court also considered 14 unopposed administrative motions to file documents under seal. Jiang filed these motions in connection with her motion to alter judgment, after judgment had been entered and the case had been closed. The materials included medical information about Jiang and her mother and other personal information unrelated to the merits of the case.

The court found that compelling reasons supported sealing the personal information and GRANTED Jiang’s administrative motions to file under seal.

Disposition

The Motion to Alter or Amend Judgment or for Relief from Judgment was denied. The administrative motions to file under seal were granted.