Jean v. US Equal Employment Opportunity Commission
- Louis Stanton
- 1:20-cv-09773
- U.S. District Court · Southern District of New York
- 4
In Jean v. US Equal Employment Opportunity Commission, Judge Stanton denied reconsideration, leaving dismissal of Jean’s suit against the agency in place.
Nathalie Jean’s case remained dismissed, and the EEOC was not required to defend the dismissed action in the district court.
What happened
In Jean v. US Equal Employment Opportunity Commission, Nathalie Jean, representing herself, asked the court to reconsider its earlier dismissal of her case against the Equal Employment Opportunity Commission. The earlier dismissal was based on the agency’s immunity from this type of lawsuit.
Jean argued that the Administrative Procedure Act allowed her to obtain judicial review of how the agency handled her matter. The court concluded that she had another adequate remedy: filing a lawsuit in federal court in Massachusetts after the agency issued its final decision. The court also found that none of the grounds for relief from a judgment applied.
Judge Stanton denied Jean’s motions under the rules governing reconsideration and relief from a judgment, including her request based on extraordinary circumstances. The court closed the case and stated that it would accept only documents directed to the U.S. Court of Appeals for the Second Circuit.
The detailed version
- Jean v. US Equal Employment Opportunity Commission · No. 1:20-cv-09773
- Louis Stanton
- May 7, 2021
Background
Nathalie Jean filed the action without a lawyer against the U.S. Equal Employment Opportunity Commission (EEOC). On December 3, 2020, the court dismissed the complaint because it determined that the EEOC was immune from the suit. Jean then submitted four letters seeking reconsideration.
The court treated Jean’s submissions as a motion under Federal Rule of Civil Procedure 59(e) to alter or amend the judgment, a motion under Local Civil Rule 6.3 for reconsideration, and, alternatively, a motion under Rule 60(b) for relief from the judgment or order.
Arguments and analysis
Jean argued that the Administrative Procedure Act (APA), including 5 U.S.C. § 702, allowed her to obtain judicial review of an EEOC office’s handling of her matter. The court explained that the APA does not provide review when the plaintiff has an adequate remedy in court. It concluded that Jean had such a remedy: after the EEOC issued its final decision, she could file a civil action in the United States District Court for the District of Massachusetts under 42 U.S.C. § 2000e-5(f).
The court therefore concluded that Jean had not shown that it overlooked controlling law or factual matters when it dismissed her case. It denied her motions under Rule 59(e) and Local Civil Rule 6.3.
The court separately considered Rule 60(b), which permits relief from a judgment for specified reasons such as mistake, newly discovered evidence, misconduct, a void judgment, or satisfaction of the judgment, as well as other reasons that justify relief. The court found that Jean had not shown that any of the first five grounds applied. It also denied relief under Rule 60(b)(6), finding that she had not shown the extraordinary circumstances required for relief under that provision.
Disposition
The court denied Jean’s motion for reconsideration, identified as ECF 10-13. The Clerk was directed to mail her a copy of the order and record service on the docket. The court stated that Jean’s case under docket number 20-CV-9773 was closed and that it would accept only filings directed to the United States Court of Appeals for the Second Circuit.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.