Sanai v. Kozinski
- Yvonne Rogers
- 4:19-cv-08162
- U.S. District Court · Northern District of California
- 6
In Sanai v. Kozinski, Judge Rogers denied Sanai’s post-judgment motions seeking to undo the judgment.
Cyrus Sanai and the defendants in his previously dismissed action; the court denied Sanai’s requests for post-judgment relief.
What happened
Cyrus Sanai, an attorney representing himself, sued various current and former federal judges, court staff, and federal and state judicial entities. After the case was dismissed based on a Rule 12 motion, he asked the court to change the judgment or grant a new trial under Rule 59 and to provide relief from the judgment under Rule 60.
Sanai argued that the earlier decision contained clear legal or factual errors and was unjust. He also focused on his arguments that the court should disclose additional information or recuse itself, meaning the judge should step aside. The court had sent those issues to Judge James Donato, who denied Sanai’s recusal or disclosure motion.
Judge Yvonne Gonzalez Rogers denied both post-judgment motions. She ruled that Sanai had not shown the extraordinary circumstances, clear error, or manifest injustice required for relief under either rule, and the order terminated the motions filed at Docket Numbers 85 and 86.
The detailed version
- Sanai v. Kozinski · No. 4:19-cv-08162
- Yvonne Rogers
- June 10, 2021
Background
Cyrus Sanai, an attorney proceeding without a lawyer, sued various current and former federal judges, court staff, and federal and state judicial entities. The action had already been dismissed based on a motion under Federal Rule of Civil Procedure 12. Sanai identified two post-judgment motions: a Rule 59 motion to alter or amend the judgment and for a new trial, and a Rule 60 motion seeking relief from the judgment and orders.
Rule 59 Motion
The court explained that Rule 59(a), which concerns a new trial, was not applicable because no trial had occurred. The court therefore considered Sanai’s request under Rule 59(e), which permits a party to ask the court to alter or amend a judgment. The court stated that this remedy is generally limited to correcting a clear legal or factual error, considering newly discovered evidence, preventing clear injustice, or responding to a change in controlling law. It also explained that Rule 59(e) cannot be used to relitigate old matters or present arguments and evidence that could have been offered before judgment.
Sanai argued that the earlier dismissal was legally or factually incorrect and unjust. The court rejected those arguments, finding that Sanai had not shown a clear or manifest error or manifest injustice. The court also rejected his continued disagreement with its conclusions that sovereign immunity barred claims against Sidney Thomas and Molly Dwyer in their official capacities and that the challenged acts were judicial acts protected by judicial immunity.
Rule 60 Motion and Recusal Issues
Sanai brought his Rule 60 motion under Rule 60(b)(6), which allows relief for another reason that justifies it. The court described Rule 60(b)(6) as an extraordinary remedy used sparingly to prevent manifest injustice. A party seeking that relief must show injury and extraordinary circumstances beyond the party’s control that prevented timely action.
Sanai’s Rule 60 motion focused exclusively on his contention that the court should recuse itself or disclose additional information under 28 U.S.C. § 455. The court had previously sent Sanai’s related recusal-or-disclosure motion to United States District Judge James Donato. Judge Donato denied that motion, finding Sanai’s recusal theories inherently unreasonable and unsupported by evidence. Judge Rogers stated that she agreed with that analysis and found that Sanai’s arguments did not meet the demanding standard for Rule 60(b)(6) relief.
Ruling
Judge Yvonne Gonzalez Rogers denied the Rule 60 motion and denied the Rule 59 motion on the recusal and disclosure ground. She also denied the remaining grounds in Sanai’s Rule 59 motion. The order states that the post-judgment motions under Rules 59 and 60 are denied and terminates Docket Numbers 85 and 86.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.