Rangel v. Williams
- Jacquelyn Corley
- 3:21-cv-00278
- U.S. District Court · Northern District of California
- 2
In Rangel v. Williams, Judge Corley denied Rangel’s reconsideration motion and set briefing deadlines in his ongoing case.
Jonathan Rangel, who represented himself, was affected by the denial of reconsideration; the defendants were affected by the briefing deadlines.
What happened
In Rangel v. Williams, Jonathan Rangel, a California prisoner without a lawyer, asked the court to reconsider its refusal to strike his deposition transcript.
Rangel argued that the defendants should have made the changes he requested to the transcript. The court found no authority requiring the defendants to make those changes and noted that Rangel could identify any further changes in his response to the summary-judgment motion.
Judge Jacqueline Scott Corley denied the reconsideration motion and set deadlines for the pending motions to compel and for summary judgment. Defendants’ opposition to the motion to compel is due March 29, 2023; Rangel’s reply is due April 12; his summary-judgment opposition is due May 12; and the reply is due May 26.
The detailed version
- Rangel v. Williams · No. 3:21-cv-00278
- Jacquelyn Corley
- Mar. 22, 2023
Background
Jonathan Rangel, a California prisoner proceeding without an attorney, moved for reconsideration of the court’s earlier order denying his motion to strike his deposition. He sought reconsideration to prevent what he described as a “manifest injustice.”
Rangel argued that the deposition should be stricken because the defendants did not make the changes he wanted to the deposition transcript. The court stated that it was aware of no authority requiring the defendants to make those changes. The court also had copies of Rangel’s requested changes and the transcript, and said Rangel could raise any additional changes he believed were warranted in his opposition to the defendants’ motion for summary judgment.
Legal standard
Because the earlier ruling did not end the case, the court considered reconsideration under Rule 54(b) of the Federal Rules of Civil Procedure. Under that rule, a nonfinal order may be revised before judgment. The court explained that reconsideration may be appropriate when there is newly discovered evidence, clear error or manifest injustice, or an intervening change in controlling law.
The court also applied Northern District of California Civil Local Rule 7-9. That rule requires a party seeking reconsideration of an interlocutory order to show a material difference in fact or law, newly emerged material facts or a change in law that could not reasonably have been presented earlier, or a manifest failure by the court to consider material facts previously presented.
Ruling and deadlines
The court found no basis to reconsider its order denying the motion to strike the deposition. It therefore denied the motion for reconsideration. The order also set these briefing deadlines:
- Defendants’ opposition to Rangel’s motion to compel: March 29,
- - Rangel’s reply on the motion to compel: April 12,
- - Rangel’s opposition to the motion for summary judgment: May 12,
- - Reply on the summary-judgment motion: May 26, 2023.
The order disposed of docket number 74.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.