Golden v. Qualcomm, Inc.

Background

The court had previously granted Qualcomm’s motion to dismiss Larry Golden’s case and entered final judgment. Golden then moved for reconsideration. Qualcomm opposed the motion, and Golden filed a document styled as “supplemental authority.”

Legal standard

The court explained that Local Rule 7-9 permits reconsideration motions for interlocutory orders—orders issued before final judgment. After final judgment, a request for reconsideration is treated as a motion to alter or amend the judgment under Federal Rule of Civil Procedure 59(e), or as a motion for relief from a judgment or order under Rule 60(b). Reconsideration is generally limited to circumstances such as a change in controlling law, newly available evidence, clear error, or manifest injustice. Rule 60(b) also identifies grounds including mistake, newly discovered evidence, fraud, a void judgment, satisfaction of the judgment, or another reason justifying relief.

Court’s ruling

The court found that Golden’s motion presented no basis for reconsidering the dismissal order or the resulting judgment. It said the motion repeated substantially the same arguments Golden had made in opposing dismissal and that he could make those arguments on appeal but could not relitigate them in the closed case. The court denied the motion and directed the clerk not to accept further filings in the case. Judge Haywood S. Gilliam, Jr. issued the order.