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N.D. Cal.Procedural orderFiled May 17, 2023

Waters v. Meta Platforms Inc.

Judge
Yvonne Rogers
Docket
4:23-cv-00643
Court
U.S. District Court · Northern District of California
Pages
2
Civil ProcedureCivil RightsMotion to Dismiss
In one sentence

In Waters v. Meta Platforms Inc., Judge Seeborg denied reconsideration because the complaint failed to state a federal conspiracy claim.

Who this affects

Rian Waters and Meta Platforms Inc. and the other named defendants; the ruling directly resolved Waters’s motion for reconsideration.

What happened

In Waters v. Meta Platforms Inc., Rian Waters asked the court to reconsider an earlier order that denied injunctive relief, dismissed the case with prejudice, and entered judgment.

The court denied the motion. It said that even if Waters was challenging only conduct in his earlier federal cases and therefore did not need to allege class-based bias, his complaint still failed to state a claim under Section 1985(2), a federal civil-rights conspiracy statute. The court also rejected his other arguments.

Chief United States District Judge Richard Seeborg issued the order as the duty judge and concluded that Waters had not met the demanding standard for changing the judgment under Rule 59(e).

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Waters v. Meta Platforms Inc. · No. 4:23-cv-00643
Judge
Yvonne Rogers
Date
May 17, 2023

Background

Rian Waters filed an “emergency motion” asking the court to reconsider an omnibus order. That earlier order denied injunctive relief, dismissed the action with prejudice, and entered judgment. The opinion does not provide the full allegations or explain the earlier order in detail.

Court’s analysis

The court addressed Waters’s argument that he intended to challenge only conduct in his prior federal actions. The court said that, even if that was his intent—and even if he therefore was not required to allege class-based animus—the complaint still failed to state a claim under 42 U.S.C. § 1985(2). Section 1985(2) is a federal statute addressing certain conspiracies that interfere with court proceedings or justice. The court also found Waters’s other arguments unpersuasive.

Ruling

The court denied the motion for reconsideration. It held that Waters had not met the “high hurdle” required to alter the judgment under Federal Rule of Civil Procedure 59(e), which governs motions asking a court to change an entered judgment.

Judge and procedural note

The order was signed by Richard Seeborg, Chief United States District Judge. The opinion explains that he entered the order because he had served as the duty judge who entered the earlier omnibus order during the temporary unavailability of the assigned judge.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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