Armatas v. Maroulleti
690 F. App'x 731
| 2d Cir. | 2017Background
- Plaintiff Panagiotis Armatas, proceeding pro se, filed a 42 U.S.C. § 1983 action that the district court dismissed in 2010; this Court affirmed the dismissal on appeal.
- Armatas later moved under Fed. R. Civ. P. 60(d)(3) to vacate the judgment, alleging defense counsel procured the judgment by submitting fraudulent documents (fraud on the court claim).
- The district court denied the Rule 60(d)(3) motion in 2015; Armatas sought reconsideration and the district court denied it in 2016.
- The 2016 order also granted a defendant’s motion for sanctions: attorneys’ fees and a limited filing injunction preventing Armatas from filing new papers in that case.
- Armatas appealed both the denial of his Rule 60(d)(3) motion/reconsideration and the sanctions; the Court of Appeals reviewed the Rule 60 denial and the injunction but dismissed the appeal as to attorneys’ fees because the amount had not been set.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rule 60(d)(3) relief is available for alleged fraud on the court | Armatas asserted defense counsel submitted fraudulent/fabricated evidence, so the judgment should be vacated | District court argued prior rejections of the same fraud claims and lack of clear, convincing evidence of fraud on the court | Denied — Rule 60(d)(3) motion and reconsideration properly denied; claims frivolous and not shown by clear and convincing evidence |
| Whether the district court abused its discretion in imposing a filing injunction/sanctions under its inherent powers | Armatas contended sanctions and injunction were improper | Defendants argued Armatas repeatedly pursued frivolous, duplicative claims despite warnings, justifying a limited filing injunction | Affirmed — limited injunction was within discretion given Armatas’s history of vexatious filings and lack of good-faith basis to prevail |
| Whether Rule 60(d)(3) motions are time-barred by Rule 60’s one-year limit | Armatas argued motion was timely because fraud on the court is exempt from the one-year limit | Defendants relied on procedural defenses but did not claim Rule 60(d)(3) is time-barred | Held — court agreed fraud-on-the-court motions are not subject to the one-year limit, but the substantive claim failed |
| Appealability of non-quantified attorneys’ fees award | Armatas challenged the fees award as part of the sanctions | Defendants sought review of sanctions including fees | Dismissed insofar as fees award was non-quantified and therefore not yet appealable |
Key Cases Cited
- United Airlines, Inc. v. Brien, 588 F.3d 158 (2d Cir. 2009) (standard of review for district court Rule 60 decisions)
- Gleason v. Jandrucko, 860 F.2d 556 (2d Cir. 1988) (fraud on the court limited to fraud that seriously affects adjudicative integrity)
- Hadges v. Yonkers Racing Corp., 48 F.3d 1320 (2d Cir. 1995) (definition of fraud on the court involving officers of the court or defilement of the court)
- King v. First Am. Investigations, Inc., 287 F.3d 91 (2d Cir. 2002) (fraud on the court must be proved by clear and convincing evidence)
- Milltex Indus. Corp. v. Jacquard Lace Co., 55 F.3d 34 (2d Cir. 1995) (circumstances permitting filing injunctions for vexatious litigation)
- Chambers v. NASCO, Inc., 501 U.S. 32 (U.S. 1991) (district courts’ inherent authority to impose sanctions)
- Safir v. U.S. Lines, Inc., 792 F.2d 19 (2d Cir. 1986) (factors for reviewing filing injunctions)