Eric Alan Sanders v. Chime Stride Bank, N.A.
- Richard Seeborg
- 3:21-cv-06068
- U.S. District Court · Northern District of California
- 3
In Sanders v. Chime Stride Bank, Judge Seeborg denied Sanders’s request to reopen his dismissed case under Rule 60(b)(6).
Eric Alan Sanders’s request to reopen his case was denied, and the case against Chime Stride Bank, N.A. remains closed.
What happened
Eric Alan Sanders asked the court to reopen his case against Chime Stride Bank, N.A. The court had dismissed the case because Sanders failed to prosecute it and comply with court deadlines.
Sanders pointed to his mother’s death, lack of income, and mental health challenges in 2021. The court said he waited more than two years to seek relief and did not adequately explain why he could not meet deadlines from August through October 2021.
Judge Seeborg denied the motion, finding that Sanders had not shown the extraordinary circumstances required for relief and that his delay, the interest in finality, prejudice to the defendant, and his ability to learn the dismissal grounds earlier weighed against reopening the case. The case remains closed.
The detailed version
- Eric Alan Sanders v. Chime Stride Bank, N.A. · No. 3:21-cv-06068
- Richard Seeborg
- Jan. 8, 2024
Background
Eric Alan Sanders filed a motion under Federal Rule of Civil Procedure 60(b)(6), which allows a court to relieve a party from a final judgment for another reason that justifies relief. Sanders sought to set aside the October 19, 2021 dismissal of his case for failure to prosecute and comply with court deadlines.
The court also addressed the timing of the judgment. It explained that a separate judgment document apparently was not entered after the dismissal order. Under Rule 58(c), when a separate document is required, judgment is entered after 150 days have passed from the civil docket entry. The court therefore determined that judgment was entered on March 18, 2022.
Sanders’s Arguments
Sanders argued that his mother’s death in May 2021, his subsequent lack of income, and mental health challenges during the summer of 2021 made it impossible for him to comply with court deadlines. The court recognized the difficulties he described, including the challenges of proceeding without a lawyer.
Court’s Analysis
A Rule 60(b)(6) motion must be made within a reasonable time. Relevant considerations include the interest in finality, the reason for the delay, the party’s practical ability to learn earlier about the grounds for relief, and prejudice to other parties. Relief under Rule 60(b)(6) is an equitable remedy used sparingly, and the moving party must show extraordinary circumstances that prevented or made the person unable to prosecute the case.
The court found Sanders’s delay unreasonable because he waited more than two years to seek relief from the dismissal and offered no explanation for that delay. The court concluded that finality, prejudice to the defendant, and Sanders’s ability to learn the grounds for dismissal earlier also weighed against granting relief.
The court further found that Sanders did not adequately explain why he could not comply with orders and deadlines from August through October 2021. Although he described a manic episode in July 2021, he did not claim that additional manic episodes during the following months prevented compliance. The court therefore found that he had not shown extraordinary circumstances preventing him from prosecuting the case during that period.
Disposition
The court denied Sanders’s motion for relief under Rule 60(b)(6). The case remains closed.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.