Hanes v. Sherburne County Jail

Background

The court previously dismissed Joshua Cameron Hanes’s complaint with prejudice in an order dated February 29, 2024. Judgment was entered on March 1, 2024. Hanes, who was representing himself, filed a Motion to Alter or Amend Judgment on March 14, 2024.

Applicable standard

The court treated the motion as one under Federal Rule of Civil Procedure 59(e), which allows a party to ask a court to change a judgment shortly after it is entered. The court found the motion timely. A Rule 59(e) motion cannot be used simply to present new legal theories, introduce evidence that could have been presented earlier, or repeat an argument already considered. To succeed, the movant must identify a mistake in the judgment or present newly discovered evidence that could not have been found before the decision.

Because Hanes had not first obtained the local court-required permission to file a reconsideration motion, the court also treated his filing as a request for that permission. The court did so because Hanes was representing himself.

Hanes’s argument and the court’s analysis

Hanes argued that his complaint properly alleged that a prison official had actual knowledge of his serious medical need and failed to act reasonably to reduce the risk of further harm. The court stated that Hanes did not provide newly discovered evidence or legal authority showing a clear legal mistake. It found that the motion merely reargued an issue the court had already considered. The court stated that it would reach the same result under Rule 60(b), another rule allowing relief from a judgment.

Disposition

The court denied Hanes’s Motion to Alter or Amend Judgment. The order did not change the earlier dismissal of the complaint with prejudice.

Judge

The order was signed by Susan Richard Nelson, United States District Judge, on March 19, 2024.