Brief Fact Summary. In assembling the lands for a National Seashore, the Petitioners, the federal government of the United States (Petitioners), in 1979 brought an action to quiet title in federal district court against the Respondents, Beggerly and others (Respondents). After agreeing to a settlement judgment, twelve years later Respondents filed suit alleging that they had new evidence and sought to re-open the original judgment.
Synopsis of Rule of Law. An independent action, under Federal Rule of Civil Procedure (FRCP) Rule 60(b), for purposes of re-opening a prior judgment beyond the statutory period for re-opening, should be available only to prevent a grave miscarriage of justice.
An independent action is available only to prevent a grave miscarriage of justice.View Full Point of Law
Issue. Whether a court should re-open a 12-year-old judgment based on new evidence.
Held. No. The Supreme Court held that the Court of Appeals erred in concluding that this was a sufficient basis to justify the reopening of the judgment from the earlier litigation. An independent action, under FRCP Rule 60(b) should be available only to prevent a grave miscarriage of justice. Concurrence. Justice John Paul Stevens (J. Stevens) concurred. His concurring opinion is omitted by the casebook.
Discussion. The court implicitly held that the only possible way for Respondents to have the district court re-open or set aside the earlier judgment was through a FRCP Rule 60(b) motion. Essentially the court is saying the availability of evidence that would have caused the earlier suit to come out differently, is not by itself a sufficient basis to re-open a judgment, absent proof that some grave injustice would result by not opening the judgmen