Komatsu v. The City of New York
- Louis Stanton
- 1:20-cv-06510
- U.S. District Court · Southern District of New York
- 4
Komatsu v. City of New York: Judge Louis Stanton denied Komatsu’s motion to undo the dismissal because it was untimely or lacked grounds.
Komatsu’s request for relief from the prior dismissal and judgment was denied, and the action remained closed.
What happened
In Komatsu v. The City of New York, the court had previously dismissed Komatsu’s action, and the Court of Appeals later affirmed that dismissal. Komatsu, who was representing himself, then sent letters asking the court to provide relief from the dismissal and judgment.
The court treated the letters as a request to change the judgment or provide relief from it. It denied relief under Rule 59(e) because the request came more than 28 days after judgment. It also denied relief under Rule 60(b)(1), (2), and (3) because the request came more than one year later, and denied relief under the other cited parts of Rule 60 because Komatsu had not shown the required grounds or extraordinary circumstances.
Judge Louis L. Stanton denied the motion and stated that the action was closed. He directed the Clerk of Court to accept documents addressed to the Court of Appeals, while warning that further frivolous or meritless filings could lead to an order requiring Komatsu to explain why additional filings should not be barred.
The detailed version
- Komatsu v. The City of New York · No. 1:20-cv-06510
- Louis Stanton
- June 3, 2022
Background
Komatsu filed this action without a lawyer. The court dismissed the action by an order issued on October 21, 2020, and entered judgment on October 22, 2020. The Court of Appeals later affirmed the dismissal. In April 2022, Komatsu filed two letters seeking relief under several Federal Rules of Civil Procedure and a federal statute concerning extraordinary court orders.
The court liberally interpreted the letters as a motion under Rule 59(e) to alter or amend the judgment, or alternatively as a motion under Rule 60(b) for relief from the final order and judgment.
Rule 59(e)
Rule 59(e) permits a party to ask the court to change or amend a judgment, but the motion must be filed within 28 days after the judgment is entered. Because Komatsu filed the first letter more than one year after the October 22, 2020 judgment, the court denied relief under Rule 59(e).
Rule 60(b)
Rule 60(b) permits relief from a final judgment for specified reasons, including mistake, newly discovered evidence, misconduct by an opposing party, a void judgment, satisfaction or reversal of the judgment, or another reason that justifies relief.
The court denied relief under Rule 60(b)(1), (2), and (3) because requests under those provisions must be filed within one year, and Komatsu’s request was late. The court also considered the arguments under Rule 60(b)(4) and (5), but found that Komatsu had not shown that those provisions applied. Finally, the court denied relief under Rule 60(b)(6), finding that Komatsu had not demonstrated the extraordinary circumstances required for relief under that provision.
Disposition
Judge Louis L. Stanton construed the April 26 and April 28 letters as one motion under Rule 59(e), or alternatively Rule 60(b), and denied the motion. The action remained closed. The court directed the Clerk of Court to accept documents addressed to the Court of Appeals. It stated that, if Komatsu filed other documents that were frivolous or meritless, the court could require him to explain why it should not bar further filings in the action.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.