Niazi Licensing Corporation v. St. Jude Medical S.C., Inc.
- Elizabeth Cowan Wright
- 0:17-cv-05096
- U.S. District Court · District of Minnesota
- 4
In Niazi Licensing v. St. Jude, Judge Wright denied NLC’s request to seek reconsideration of an attorneys’ fees award.
Niazi Licensing Corporation’s local counsel, who sought permission to challenge the earlier attorneys’ fees order, and St. Jude Medical S.C., Inc., the recipient of that fees award.
What happened
Niazi Licensing Corporation asked for permission to file a motion reconsidering an earlier order that had granted St. Jude Medical S.C., Inc.’s request for attorneys’ fees in part. NLC’s local counsel argued that they should not be responsible because their role was limited.
The court found that local counsel had not shown the required compelling circumstances. It said the record supported holding them responsible for filings made in NLC’s name and that any new arguments or evidence should have been presented earlier.
Judge Wright denied Niazi Licensing Corporation’s request for permission to file a motion for reconsideration. The earlier attorneys’ fees order therefore remained in place as addressed by this order.
The detailed version
- Niazi Licensing Corporation v. St. Jude Medical S.C., Inc. · No. 0:17-cv-05096
- Elizabeth Cowan Wright
- Nov. 18, 2021
Background
The court considered an October 27, 2021 letter request from Niazi Licensing Corporation’s (NLC’s) local counsel. They asked for permission to file a motion for reconsideration of the court’s October 25, 2021 order, which had granted in part St. Jude Medical S.C., Inc.’s request for attorneys’ fees.
Local Rule 7.1(j) requires a party to obtain the court’s permission before filing a motion for reconsideration. Permission requires a showing of “compelling circumstances.” Reconsideration is limited to correcting a clear legal or factual error or considering newly discovered evidence; it cannot be used to repeat earlier arguments or present arguments, evidence, or legal theories that could have been raised earlier.
Arguments and analysis
NLC’s local counsel did not claim to have newly discovered evidence. Instead, they argued that the attorneys’ fees order contained legal and factual errors because their responsibilities as local counsel were limited.
The court rejected that argument. In the earlier fees order, it had found that NLC’s attorneys had repeatedly relied on undisclosed evidence, disregarded scheduling deadlines, violated an order striking improper evidence, and advanced unreasonable and meritless arguments. The court had concluded that this conduct showed intentional and reckless disregard of the attorneys’ duties and warranted sanctions.
The court explained that NLC’s local counsel had been involved since the case began and that their names appeared in the signature block of NLC’s submissions, including submissions connected to the sanctionable conduct. Local Rule 83.5(d)(2)(A) required local counsel to participate in preparing and presenting the case. The court stated that the record therefore did not show a legal or factual error concerning the scope of the fees order. It also stated that, even if local counsel had arguments or evidence supporting their position, those matters were untimely because they could have been presented when NLC opposed St. Jude’s fees request.
Disposition
The court concluded that NLC’s local counsel had not demonstrated the required compelling circumstances. It denied Plaintiff Niazi Licensing Corporation’s request for leave to file a motion for reconsideration, Docket 336.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.