Wood v. County of Contra Costa

Background

On October 14, 2020, the clerk entered judgment based on the court’s orders dismissing all claims in the plaintiffs’ First Amended Complaint. The court had dismissed Andrea Wood’s claims without further permission to amend because they failed to state a claim. It had dismissed T.P.’s claims without prejudice because T.P. was a minor who was not represented by counsel.

Wood, proceeding without a lawyer, submitted a motion received January 4, 2021, seeking relief from the final judgment so she could file a Second Amended Complaint. She did not submit a proposed Second Amended Complaint, although the opinion states that she described it in her motion.

Court’s Reasoning

The court explained that, after judgment has been entered, a motion to amend the complaint can be considered only if the judgment is first reopened under Federal Rule of Civil Procedure 59 or 60. Wood relied on Rule 60, which permits relief from a judgment for specified reasons. The court found that Wood had not identified any legally recognized reason for granting that relief.

Ruling

The court denied Wood’s motion for relief from judgment. It did not reopen the judgment or authorize the filing of a Second Amended Complaint.

The court also directed the clerk to file under seal the 193 pages of documents Wood submitted as exhibits to her Rule 60 motion. The court found that the exhibits contained material that was not properly filed in the public record and that could be filed under seal without redaction under the cited court rule. Judge INE M. CHESNEY signed the order.