Walker v. Krol
- Haywood Gilliam
- 4:15-cv-05819
- U.S. District Court · Northern District of California
- 5
In Walker v. Krol, Judge Gilliam denied Walker’s request to vacate the judgment, leaving the case closed.
Jeffrey E. Walker’s request to reopen his previously dismissed civil-rights case was denied, so the case remains closed; the defendants retain the benefit of the 2017 judgment.
What happened
In Walker v. Krol, Jeffrey E. Walker, who was representing himself, asked the court to reopen his civil-rights case. The court had dismissed the case in 2017 after Walker repeatedly refused to attend a deposition and did not respond to the court’s orders.
Walker said he had been unable to pursue the case for several years because he was forcibly given antipsychotic medication. The defendants opposed reopening the case, arguing that Walker had not shown an extraordinary circumstance and had waited too long to seek relief.
Judge Haywood S. Gilliam, Jr. denied Walker’s request under the rule allowing a judgment to be set aside in extraordinary circumstances. The court found that Walker had not adequately explained how the medication prevented him from pursuing the case, had not acted diligently, and had waited nearly five years after the judgment. The case remains closed.
The detailed version
- Walker v. Krol · No. 4:15-cv-05819
- Haywood Gilliam
- July 29, 2022
Background
Jeffrey E. Walker, an inmate housed at San Francisco County Jail, filed this action without a lawyer under 42 U.S.C. § 1983. He alleged that conditions at the jail violated the Fourteenth Amendment while he was a pretrial detainee in or around June 2015.
In 2017, the court ordered Walker to explain why it should not dismiss the case because he repeatedly refused to attend his deposition, preventing the defendants from gathering evidence about his allegations. Walker did not oppose the defendants’ dismissal motion or respond to the court’s order. On August 7, 2017, the court dismissed the case with prejudice for failure to prosecute under Federal Rule of Civil Procedure 41(b).
In January 2022, more than four years later, Walker asked to proceed with the case. The court treated that request as a motion under Federal Rule of Civil Procedure 60(b)(6), which allows a court to set aside a judgment only in extraordinary circumstances to prevent serious injustice.
Arguments
Walker said he had been unable to prosecute the case because he was forcibly given antipsychotic medication from November 2016 through 2021. He also said he had been partially sedated and could not proceed with the deposition. Walker attached state-court filings and said he had pursued other legal matters during the relevant period.
The defendants opposed relief. They argued that Walker’s description of his impairment was too vague to establish extraordinary circumstances and that he had not filed his motion within a reasonable time. The defendants also initially argued that reopening the case was barred by claim preclusion and the statute of limitations.
Court’s analysis
The court applied factors concerning extraordinary circumstances, diligence, the importance of finality, the delay between the judgment and the motion, and the connection between the alleged extraordinary circumstance and the judgment.
The court found that the extraordinary-circumstances factor weighed against Walker because he did not explain what medication he received or how partial sedation prevented him from prosecuting the case for more than four years. The court also noted that he did not explain how he was able to pursue multiple state-court cases or why he did not promptly pursue this case after he stopped taking the medication.
The diligence factor also weighed against Walker because he had pursued other court actions since sometime in 2021 but did not file this motion until January 2022. The court found that finality and the nearly five-year delay also weighed against him. The connection between the alleged medication-related impairment and the request to reopen the case was neutral.
Disposition
The court concluded that Walker had not shown the extraordinary circumstances or serious injustice required for relief under Rule 60(b)(6). Judge Haywood S. Gilliam, Jr. denied Walker’s motion to vacate the judgment. The case remains closed, and the order terminated Docket No. 38.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.