Bouret-Echevarría v. Caribbean Aviation Maintenance Corp.
784 F.3d 37
| 1st Cir. | 2015Background
- A helicopter crash in November 2008 killed Diego Vidal-Gonzalez; his widow and three minor children sued Robinson Helicopter Co. and CAM for products liability.
- The jury verdict in February 2012 found no negligence by CAM and no defect by Robinson; final judgment entered March 19, 2012; motion for a new trial denied May 9, 2012.
- Appellants later learned, more than a year after judgment, that jurors allegedly knew of a confidential settlement offer and that this may have tainted deliberations.
- Affidavits from Bouret-Echevarria and Angueira alleged that aviation expert Irizarry relayed information about juror knowledge of the settlement; the information traced to employer statements
- The district court denied the Rule 60(b)(6) motion as untimely and based on hearsay; appellants appealed challenging the denial and seeking an evidentiary hearing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Timeliness under 60(b)(6) | Appellants contended eighteen months was reasonable given attempts to substantiate. | Defendants argued delay pushed limits of reasonableness and was untimely. | Appellate panel held the district court abused discretion; timeliness should be measured from notice and efforts to obtain evidence, not final judgment alone. |
| Exceptional circumstances under 60(b)(6) | If jurors knew of a settlement, due process was violated and extraordinary relief is warranted. | Allegations were unsubstantiated rumors; extraordinary relief not justified. | Court found potential exceptional circumstances if true, warranting investigation and relief. |
| Meritorious claim requirement | There was merit to the claim that juror misconduct affected the verdict. | No clear meritorious claim established from the affidavits without an evidentiary airing. | Court concluded there could be a potentially meritorious claim, justifying a hearing to test the evidence. |
| Unfair prejudice to CAM/Robinson | Granting relief would not be inherently prejudicial and would protect due process. | Re-litigating would cause prejudice and burden. | Prejudice concerns did not outweigh due process; controlled hearing could mitigate. |
| Right scope of evidentiary hearing | District court should hold an evidentiary hearing to test fact-specific statements and possible juror contact. | Hearsay and rumor require cautious handling and may not justify a hearing. | The court should convene a limited evidentiary hearing to assess the fact-specific statements and then decide on 60(b)(6) relief. |
Key Cases Cited
- Teamsters, Chauffeurs, Warehousemen & Helpers Union, Local No. 59 v. Superline Transp. Co., 953 F.2d 17 (1st Cir.1992) (balances finality with relief via Rule 60(b)(6))
- Liljeberg v. Health Servs. Acquisition Corp., 486 U.S. 847 (Supreme Court 1988) (requirements for extraordinary relief under 60(b)(6))
- Pioneer Highs. Servs. Co. v. Brunswick Assocs. Ltd. P’ship, 507 U.S. 380 (Supreme Court 1993) (timing and diligence in Rule 60(b) motions)
- Ungar v. Palestine Liberation Org., 599 F.3d 79 (1st Cir.2010) (holistic analysis of Rule 60(b)(6) factors)
- United States v. Connolly, 341 F.3d 16 (1st Cir.2003) (test for extraneous information under Rule 606(b))
- United States v. Boylan, 898 F.2d 230 (1st Cir.1990) (preference for evaluating prejudice to jurors)