Harper v. Trumbull

Background

Paul Harper filed a motion to alter or amend the judgment previously entered in the case. The court had earlier granted Patricia V. Trumbull’s motion to dismiss on judicial-immunity grounds. The Clerk then entered judgment for Trumbull and closed the case. Harper later requested entry of default, which the Clerk declined, and then filed the motion addressed in this order.

Because Harper was representing himself and the filing was unclear, the court treated it liberally as a request for reconsideration under Federal Rules of Civil Procedure 59(e) and 60(b). A motion under Rule 59(e) asks the court to alter or amend a judgment. Rule 60(b) allows relief from a final judgment for specified reasons or, in some circumstances, another reason that justifies relief.

Arguments and analysis

The court said Harper appeared to argue that Trumbull’s failure to appear or defend the case after her death invalidated the court’s later ruling on her motion to dismiss. The court rejected that argument. It also addressed Harper’s disagreement with describing the case as a civil-rights action and with the applicable filing deadline. The court explained that its earlier dismissal had expressly said it did not need to decide whether Harper’s claims were time-barred.

The court stated that the decisive point was that Trumbull was absolutely immune from civil liability for acts performed in her judicial capacity as a federal magistrate judge. The court said Harper had not adequately pleaded, and could not adequately plead, that the judicial acts at issue occurred in the complete absence of jurisdiction.

The court further held that the motion was untimely under Rule 59(e) because Harper filed it more than 28 days after judgment was entered. Even if it had been timely, the court found that Harper had not identified newly discovered evidence, a clear error, a manifestly unjust decision, or an intervening change in controlling law. The court also found no basis for relief under Rule 60(b).

Ruling and effect

Judge Haywood S. Gilliam, Jr. DENIED the motion to alter or amend the judgment. The earlier judgment for Trumbull and the closure of the case therefore remained in place. The court stated that it would accept no further filings in the closed case and that an appeal was the sole appropriate recourse if Harper continued to disagree with the orders and judgment.

Classification

This is a procedural order because the court denied a motion seeking reconsideration of an earlier judgment rather than deciding a new underlying claim on the merits.