Munt v. Schnell
- Wilhelmina Wright
- 0:19-cv-01560
- U.S. District Court · District of Minnesota
- 4
In Munt v. Schnell, Judge Wright denied Munt’s motion for relief from judgment, finding none of his Rule 60 arguments justified it.
Joel Marvin Munt’s request to undo the prior judgment was denied. The September 2, 2020 dismissal was not disturbed by this order.
What happened
In Joel Marvin Munt v. Paul Schnell et al., Munt asked the court to undo its September 2, 2020 dismissal of his case against Minnesota Department of Corrections employees.
Munt argued that the court had overlooked his claim that disciplinary rules were unconstitutional, misstated the conduct involved, improperly resolved a factual dispute, failed to draw reasonable conclusions in his favor, and denied him permission to amend his complaint.
The court denied Munt’s motion because none of the cited Rule 60 grounds applied. It also said reconsideration was not warranted because Munt had not obtained permission to file that type of motion or shown compelling circumstances. Judge Wilhelmina M. Wright issued the order.
The detailed version
- Munt v. Schnell · No. 0:19-cv-01560
- Wilhelmina Wright
- Apr. 19, 2021
Background
Joel Marvin Munt sued Paul Schnell and other defendants who work for the Minnesota Department of Corrections. On September 2, 2020, the court granted the defendants’ motion to dismiss. Munt then moved for relief from that judgment under Rule 60 of the Federal Rules of Civil Procedure.
Munt’s arguments
Munt invoked Rule 60(b)(1), (4), and (6). He argued that the court had not addressed his claim that the disciplinary rules were unconstitutional, had misrepresented the conduct at issue and improperly resolved a factual dispute, had failed to draw reasonable inferences, and had failed to give him leave to amend. The court understood Munt to be challenging the September 2, 2020 order and seeking review of its conclusions.
Rule 60 analysis
The court denied relief under Rule 60(b)(1), which permits relief for mistake, inadvertence, surprise, or excusable neglect. The court explained that this provision does not provide relief merely because a party believes the court made a legal error. Because Munt did not identify an error covered by Rule 60(b)(1), relief on that ground was not warranted.
The court also denied relief under Rule 60(b)(4), which applies when a judgment is void. A judgment is void if the court lacked jurisdiction or acted inconsistently with due process. The court said Munt had not argued that either circumstance existed.
Finally, the court denied relief under Rule 60(b)(6), which allows relief for another reason that justifies it. The court described this as an extraordinary remedy available only in exceptional circumstances. It found that Munt had not explained why that remedy was warranted or identified exceptional circumstances.
Reconsideration
To the extent Munt sought reconsideration of the September 2, 2020 order, the court said he had not followed the District of Minnesota’s procedure. Local Rule 7.1(j) requires permission before filing a motion for reconsideration, and permission requires a showing of compelling circumstances. The court said Munt had not requested permission and, even construing his motion as such a request, had not shown compelling circumstances. The court therefore said reconsideration was not warranted.
Disposition
Judge Wilhelmina M. Wright ordered that Munt’s motion for relief from judgment, docket entry 78, is DENIED.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.