Trivedi v. General Electric Company

Background

Madhuri Trivedi filed this action without a lawyer. The court stated that the claims in her complaint had been raised and adjudicated in two earlier actions in the District of Massachusetts. On February 6, 2023, the court dismissed this action as barred by claim preclusion, a rule that prevents a party from relitigating claims that were previously resolved. The court also ordered Trivedi to show cause—meaning explain why—she should not be barred under 28 U.S.C. § 1651 from filing additional actions in this court without first obtaining permission.

After that order, Trivedi contacted the judge’s chambers twice despite an earlier direction not to do so. She then filed three motions seeking recusal, reassignment to another judge, and a conference call. Her filings also challenged the February 6 dismissal.

Recusal ruling

The court denied the motions seeking recusal. Recusal is a judge’s withdrawal from a case when the judge’s impartiality might reasonably be questioned. The court explained that judicial rulings ordinarily are not a valid basis for recusal. It found that Trivedi’s filings showed dissatisfaction with the court’s decisions but did not state facts showing deep-seated favoritism or antagonism that would make fair judgment impossible. The court stated that disagreement with judicial rulings is ordinarily addressed through an appeal, not a recusal motion.

Reconsideration and relief from judgment

The court treated Trivedi’s submissions, to the extent they sought review of the February 6 order, as requests under Local Civil Rule 6.3, Federal Rule of Civil Procedure 59(e), and Rule 60(b). The court denied reconsideration under each provision.

Under Rule 59(e) and Local Civil Rule 6.3, Trivedi had to show that the court overlooked controlling law or factual matters previously presented. The court found that she had not made that showing.

Under Rule 60(b), a party may seek relief from an order or 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 found that Trivedi had not shown that any of the first five categories 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.

Conclusion and other dispositions

The court denied Trivedi’s motions for recusal, identified as ECF Nos. 6, 8, and 9. It also denied her arguments and requests for reassignment and reconsideration, denied her request for a conference call, and terminated all other matters. The court stated that Trivedi had 30 days from the February 6 order to show cause why she should not be barred from filing future actions in this court without permission. The court again directed her not to contact chambers.

The court certified under 28 U.S.C. § 1915(a)(3) that an appeal from this order would not be taken in good faith and denied permission to appeal without paying filing fees for that appeal.