Goodman v. Sharp
- Valerie Caproni
- 1:21-cv-10627
- U.S. District Court · Southern District of New York
- 10
In Goodman v. Sharp, Judge Caproni denied Goodman’s motion for reconsideration of the dismissal, finding no overlooked authority, evidence, or exceptional circumstances.
Jason Goodman, who sought to reopen the dismissal of his amended complaint, and the defendants opposing that request.
What happened
In Goodman v. Sharp, Jason Goodman asked the court to reconsider its dismissal of his amended complaint. He filed the motion without a lawyer and relied on rules allowing relief from a final order for misconduct, fraud, or other exceptional reasons.
Goodman argued that the defendants had engaged in fraud, attorney misconduct, and other wrongdoing, and that the court had treated him unfairly and failed to read his allegations liberally. The defendants’ positions are not described in the order.
Judge Valerie Caproni ruled that the motion was timely under the rule governing relief from a final order, even though it was late under the local reconsideration rule. She denied the motion because Goodman had not identified overlooked authority or evidence, or shown exceptional circumstances, and had repeated arguments the court had already rejected.
The detailed version
- Goodman v. Sharp · No. 1:21-cv-10627
- Valerie Caproni
- Sept. 6, 2022
Background
Jason Goodman, representing himself, moved under Federal Rule of Civil Procedure 60(b)(3), 60(b)(6), and 60(d)(3) for reconsideration of the court’s dismissal of his amended complaint. The defendants named in the caption are Adam Sharp, Terrance O’Reilly, Frank Scherma, Margaret Esquenet, National Academy of Television Arts and Sciences, Inc., and Academy of Television Arts and Sciences, Inc.
Goodman’s Arguments
Goodman argued that the court had treated him unfairly and had failed to read his filings liberally. He alleged that the defendants had coordinated with David George Sweigert, used information against him, engaged in misconduct involving a confidential email address, and forged his electronic signature on court filings. He also argued that these allegations supported relief for fraud on the court and that the court should punish the alleged misconduct even if his earlier motions were procedurally defective.
Timeliness and Rule 60 Standards
The court stated that Local Rule 6.3 generally requires a motion for reconsideration to be served within 14 days after entry of the judgment. Although Goodman’s motion was untimely under that rule, the court treated it as timely under Rule 60(b), which allows a motion within no more than one year after the judgment, order, or proceeding.
Rule 60 permits relief from a final judgment or order only in limited circumstances. Rule 60(b)(3) concerns fraud, misrepresentation, or misconduct by an opposing party; Rule 60(b)(6) covers another reason that justifies relief; and Rule 60(d)(3) preserves the court’s power to set aside a judgment for fraud on the court. The court explained that this is extraordinary relief requiring exceptional circumstances, and that reconsideration generally requires the movant to identify controlling decisions or data the court overlooked.
Ruling
The court found that Goodman had not provided authority or evidence that it had overlooked and had not shown exceptional circumstances supporting relief. It also found that he had repeated the same arguments about fraud and attorney misconduct that the court had already rejected. The court therefore denied Goodman’s motion for reconsideration.
Disposition
The motion for reconsideration was denied. The order did not alter the earlier dismissal of the amended complaint.
Read the full 10-page opinion on CourtListener, the free public archive maintained by the Free Law Project.