Harris v. Maplewood Police Department

Background

Anthony Harris, representing himself, brought claims under 42 U.S.C. § 1983 against the Maplewood Police Department and Menards. He claimed that he was arrested without probable cause while shopping at Menards, subjected to excessive force, and arrested because of racial profiling. The caption also lists John Doe, Arresting Officer, as a defendant.

Menards’s motion to dismiss for failure to state a claim was granted in an earlier order. After discovery closed, the Maplewood Police Department moved to dismiss as a discovery sanction and also moved for summary judgment. The court adopted a recommendation that Harris’s discovery violations did not prejudice the Police Department because it could file a summary-judgment motion. As a sanction, however, the court barred Harris from introducing or using the requested discovery in his claims or defenses.

The court granted Harris a 60-day extension to oppose summary judgment, but he did not file an opposition brief. On March 28, 2019, the court granted the summary-judgment motion, dismissed the action with prejudice, and entered judgment for the defendants.

Motion for relief from judgment

Harris moved under Federal Rule of Civil Procedure 60(b)(1) and (b)(6). Rule 60(b)(1) permits relief from a judgment for mistake, inadvertence, surprise, or excusable neglect. Rule 60(b)(6) permits relief for another reason justifying relief, but the court described that provision as an extraordinary remedy for exceptional circumstances.

Harris said he was unfamiliar with the court system and might have inadvertently discarded paperwork. He also cited health problems, difficulties with the prison law library, and the process used to store paperwork. He provided no further information about those problems and did not explain how they prevented him from filing an opposition to summary judgment.

Ruling

The court denied the motion. Under Rule 60(b)(1), the court explained, neglect must involve good faith and a reasonable basis for failing to follow the rules. The court found that Harris had not shown sufficient grounds for relief. It also stated that being self-represented does not excuse a party from complying with substantive and procedural law.

The court separately denied relief under Rule 60(b)(6). It found that Harris was asserting the same grounds under both subsections and could not use those same facts to establish exceptional circumstances after failing to qualify for relief under Rule 60(b)(1). The court ordered that Harris’s Motion for Relief from Judgment was DENIED.