Patino Mancia v. County of Westchester

Background

Mauricio Antonio Patino Mancia filed the action without a lawyer against the County of Westchester, Westchester County Jail, and Judge Susan Cacace. On December 5, 2022, the court dismissed the complaint under claim preclusion. Claim preclusion is a rule that generally prevents a party from pursuing claims arising from the same transactions or occurrences that were, or could have been, presented in an earlier case.

Patino Mancia then filed a motion titled “Motion To Reconsider.” The court interpreted that filing as seeking relief under three provisions: Federal Rule of Civil Procedure 59(e), which allows a party to ask the court to alter or amend a judgment; Local Civil Rule 6.3, which governs reconsideration in that court; and Federal Rule of Civil Procedure 60(b), which permits relief from a judgment for specified reasons.

Court’s Analysis

For the Rule 59(e) and Local Civil Rule 6.3 requests, the court applied the requirement that the moving party identify controlling law or factual matters that the court had overlooked. The court concluded that Patino Mancia had not made that showing. It relied on its determination that his claims arose from the same transactions and occurrences addressed in a prior related proceeding and therefore were barred by claim preclusion. The court denied the motion under both Rule 59(e) and Local Civil Rule 6.3.

The court also denied relief under Rule 60(b). It found that Patino Mancia had not shown that any of the grounds in the rule’s first five clauses applied, including mistake, newly discovered evidence, misconduct, a void judgment, or satisfaction or reversal of the judgment. The court separately denied relief under Rule 60(b)(6), which allows relief for another reason that justifies it, because Patino Mancia had not shown extraordinary circumstances.

Disposition

The court denied Patino Mancia’s motion for reconsideration, terminated all other matters, and closed the action. It directed the Clerk of Court to accept only documents directed to the United States Court of Appeals for the Second Circuit. The court also stated that it could require Patino Mancia to explain why he should not be barred from filing further documents in this action if he submitted additional frivolous or meritless documents.

Finally, the court certified that any appeal from the order would not be taken in good faith and denied permission to appeal without paying filing fees. The opinion does not state that the denial of reconsideration was issued with or without prejudice.