WINFREY v. FORD MOTOR COMPANY (2021)

United States Court of Appeals, Eighth Circuit.2021-03-29No. No. 20-2911

Summary · law.co

Holding. The appellate court affirmed the district court's denial of Winfrey's motion for reconsideration under Federal Rule of Civil Procedure 60(b).

Hollis Winfrey filed an employment discrimination lawsuit against Ford Motor Company in November 2019 as a self-represented litigant. The district court dismissed his complaint in April 2020, finding that some claims were filed too late and others did not adequately state legal violations. Winfrey later asked the district court to reconsider its dismissal, arguing he had valid reasons for not meeting the filing deadlines, but the district court denied this request in August 2020.

Winfrey appealed the district court's denial of his reconsideration motion. On appeal, the court first determined that it could only review whether the district court properly denied the reconsideration motion itself, not the underlying dismissal, because Winfrey's appeal notice was filed within the required timeframe only for that denial. The appellate court then examined whether the district court abused its authority in refusing to set aside the dismissal. Applying the proper legal standard, the court concluded the district court acted reasonably and did not abuse its discretion.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

Appellate jurisdiction over orders denying motions for reconsideration
Standards for obtaining relief from final judgment under Rule 60(b)
Whether untimely employment discrimination claims may be revived
Discretionary review of decisions denying reconsideration motions

Procedural posture

Winfrey appealed the district court's August 2020 order denying his motion for reconsideration of an April 2020 judgment dismissing his employment discrimination complaint.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion · public domain

[Unpublished]

Hollis Winfrey appeals following the district courts

denial of his motion seeking reconsideration of the judgment dismissing this employment discrimination action. For the following reasons, we affirm.

In November 2019, Winfrey filed his pro se complaint, naming his former employer, Ford Motor Company. The district court thereafter granted Fords motion to dismiss the complaint, concluding, inter alia, that some of Winfreys claims were untimely, while others failed to state a claim. Judgment was entered on April 1, 2020. In July, Winfrey moved for “reconsideration,” asserting, for various reasons, that he was unable to timely raise his claims. On August 20, the district court entered an order denying the motion, concluding that Winfreys arguments did not merit relief under, as relevant, Federal Rule of Civil Procedure 60(b)(1) (court may relieve party from final judgment or order due to, inter alia, mistake, inadvertence, surprise, or excusable neglect). On September 11, Winfrey filed his notice of appeal (NOA). On appeal, he challenges the district courts dismissal of his complaint, and asserts that he was entitled to relief under Rule 60(b).

Initially, we conclude that appellate jurisdiction is limited to the district courts order denying Winfreys motion for reconsideration under Rule 60(b), as that is the only order which he timely appealed. See Fed. R. App. P. 4(a) (NOA must be filed within 30 days after entry of judgment or order appealed from; if party filed, inter alia, motion under Rule 60 no later than 28 days after entry of judgment, time to file appeal runs from entry of order disposing of such motion); see also United States v. Stute Co., 402 F.3d 820, 822 (8th Cir. 2005) (timely filing of NOA is mandatory and jurisdictional). We further conclude, after careful review of the record and the parties’ arguments on appeal, that the district court did not abuse its discretion in denying relief under Rule 60(b). See Giles v. Saint Lukes Northland-Smithville, 908 F.3d 365, 368 (8th Cir. 2018) (per curiam) (standard of review; reversal of denial of Rule 60(b) motion is rare, as it only authorizes relief in exceptional circumstances).

Accordingly, we affirm. See 8th Cir. R. 47B.

FOOTNOTES

. The Honorable Greg Kays, United Stated District Judge for the Western District of Missouri.

PER CURIAM.