Jones v. Lincoln Electric Co.

Brief Fact Summary.

Jones sued wedding rod manufacturers claiming that he suffered brain damage due to manganese exposure.

Synopsis of Rule of Law.

A district court is eligible to deny a motion for relief from a final judgment under FRCP 60(b) if the moving party cannot show that a new trial with newly introduced evidence will not yield a different result.

Facts.

Jones sued wedding rod manufacturers claiming that he suffered brain damage due to manganese exposure. Only Jones’ expert testified that Jones suffered from manganese exposure, while other doctors diagnosed Jones with idiopathic Parkinson’s disease. The jury found for the defendants. Jones moved for relief from the verdict on the claim that Dr. Eager, the defendants’ expert witness, testified falsely. The district court did not grant relief to Jones because he knew of Eager’s study throughout the trial.

Issue.

Whether a district court may deny a motion for relief from a final judgment under FRCP 60(b)?

Held.

Yes. The denial of Jones’ 60(b) motion is affirmed. The evidence introduced by Jones was not material.

Discussion.

A district court is eligible to deny a motion for relief from a final judgment under FRCP 60(b) if the moving party cannot show that a new trial with newly introduced evidence will not yield a different result. A new trial based on newly discovered evidence should be granted if: (1) the evidence wasn’t discovered until after the trial, (2) the moving party exercised due diligence, (3) the newly discovered evidence is not cumulative or serves to impeach, (4) the newly discovered evidence is material, (5) a new trial with newly discovered evidence would yield a new result.