Bruzzese v. Garland, 21-1448-cv

Adam Bruzzese, pro se, sued the ATF under the Rehabilitation Act challenging his 2009 reassignment; the district court granted summary judgment to the ATF, and this Court affirmed on appeal.
After judgment, Bruzzese filed motions to unseal records and for a hearing, raising new due-process arguments tied to the same 2009 reassignment.
The district court treated those post-judgment filings as motions under Federal Rule of Civil Procedure 60(b) to vacate or set aside the judgment and denied relief; Bruzzese appealed.
The Second Circuit considered whether the filings were properly treated as Rule 60(b) motions and whether Bruzzese met standards for relief, focusing on Rule 60(b)(2) (newly discovered evidence) and Rule 60(b)(4) (void judgment).
The Court concluded most of the evidence Bruzzese relied on was produced during pre-judgment discovery (thus not "newly discovered"), and he failed to show any newly discovered evidence would likely have changed the outcome.
The Second Circuit affirmed the district court’s denial of Rule 60(b) relief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether post-judgment filings should be treated as Rule 60(b) motions	Bruzzese characterized the filings as motions to unseal and for a hearing to pursue a due-process claim	The filings sought to relitigate or amend claims after final judgment and thus are properly treated as Rule 60(b) motions	Court properly construed the filings as Rule 60(b) motions
Whether Rule 60(b)(2) relief (newly discovered evidence) is warranted	Evidence was sealed or learned post-judgment and thus could not have been raised earlier	Most evidence was produced in pre-judgment discovery; Bruzzese showed no newly discovered evidence that would have changed the result	60(b)(2) relief denied; evidence not newly discovered or not outcome-determinative
Whether Rule 60(b)(4) relief (judgment is void) applies	Bruzzese contended due-process defects render the judgment void	No basis shown that the judgment was void for lack of jurisdiction or due-process failure	60(b)(4) did not apply; de novo review inapplicable; denial affirmed

Ruotolo v. City of New York, 514 F.3d 184 (2d Cir. 2008) (amending complaint after final judgment requires vacating judgment under Rule 60(b))
United States v. Int’l Bhd. of Teamsters, 247 F.3d 370 (2d Cir. 2001) (elements for Rule 60(b)(2) newly discovered evidence)
United Student Aid Funds, Inc. v. Espinosa, 559 U.S. 260 (U.S. 2010) (Rule 60(b)(4) applies only when judgment is void due to lack of jurisdiction or due-process violation)
Meilleur v. Strong, 682 F.3d 56 (2d Cir. 2012) (standard of review for Rule 60(b) motions; de novo for 60(b)(4))
Paddington Partners v. Bouchard, 34 F.3d 1132 (2d Cir. 1994) (Rule 60(b) provides extraordinary relief and requires exceptional circumstances)
Nat’l Petrochemical Co. of Iran v. M/T Stolt Sheaf, 930 F.2d 240 (2d Cir. 1991) (cannot amend complaint unless prior judgment is vacated)
Bertin v. United States, 478 F.3d 489 (2d Cir. 2007) (courts construe pro se submissions to raise the strongest arguments)