Knight v. The City of New York

Background

On May 1, 2020, the court granted the defendants’ motion to dismiss Freddie Knight’s complaint. The court allowed Knight 30 days to file an amended complaint. Because the thirtieth day fell on May 31, 2020, the filing deadline became June 1 under the federal rule governing how deadlines are calculated.

Knight did not file an amended complaint by that deadline. The court waited two additional weeks, then directed the Clerk of Court to enter judgment for the defendants and close the case. The court later learned that Knight had dated a request for an extension of time on June 7, 2020, and that the court did not receive it until June 17.

Knight was incarcerated and proceeding without a lawyer. He said he was legally blind and had difficulty understanding printed materials without help from other inmates. He also cited pandemic-related social-distancing instructions, his underlying medical conditions, and a four-to-ten-day delay in using the facility’s law library. He requested until August 30, 2020, to amend his complaint.

Rule 60(b)(6) analysis

Because judgment had already been entered, the court treated Knight’s extension request as including a motion to vacate the judgment under Federal Rule of Civil Procedure 60(b). That rule allows a court to provide relief from a final judgment for specified reasons. The court analyzed the request under Rule 60(b)(6), which covers any other reason that justifies relief.

The court explained that Rule 60(b)(6) relief requires extraordinary circumstances. Courts also generally require highly convincing evidence, a good reason for not acting sooner, and no undue hardship to the other parties. The court noted that restrictions associated with incarceration, including limited law-library access and delays in receiving materials, generally have not been treated as extraordinary circumstances.

Ruling

Judge Gregory H. Woods held that the circumstances Knight described did not meet the extraordinary-circumstances standard. The court also found that Knight had not provided highly convincing evidence because his only evidence was an unsworn letter. Although the letter gave a reason why Knight may have been unable to file an amended complaint on time, the court concluded that it did not explain why he could not submit a straightforward extension request within the 30-day period.

The court denied Knight’s motion to vacate the judgment and for an extension of time to file an amended complaint. It also certified that any appeal from the order would not be taken in good faith and denied Knight fee-free status for purposes of an appeal. The Clerk of Court was directed to mail Knight a copy of the order.