Father M v. Various Tort, 667 F. App'x 601

Father M appealed the district court’s denial of his Rule 60(b)(6) motion for reconsideration after an adverse judgment.
He submitted new declarations about his living situation after the underlying decision and argued those warranted relief.
The district court denied relief, finding Father M failed to show the required "extraordinary circumstances."
The court observed the new information could have been raised earlier and was not newly discovered or unavailable.
The district court also found no clear, authoritative change in governing law that would justify reopening the case.
Father M argued his facts warranted reconsideration under the good-cause/good-reason balancing standard applied in this circuit.

Issue	Father M's Argument	Opposing Argument	Held
Whether Rule 60(b)(6) relief is warranted	New declarations about living situation justify relief	Declarations were available earlier; no extraordinary circumstances	Denied — no abuse of discretion; relief requires extraordinary circumstances
Whether new evidence was unavailable earlier	Evidence is new and material	Evidence could have been presented earlier; not excusable delay	Denied — failure to explain why evidence was not raised previously
Whether a change in governing law occurred	Application of good-cause standard to his facts supports relief	No clear, authoritative change in law occurred	Denied — no change in law; same standard applied throughout litigation
Whether this case is analogous to prior successful 60(b)(6) motions	Analogous to other cases that warranted reconsideration	District court found factual dissimilarity and other deficiencies	Denied — dissimilarity noted but not sole basis; overall discretion not abused

Navajo Nation v. Confederated Tribes & Bands of the Yakama Indian Nation, 331 F.3d 1041 (9th Cir. 2003) (standard of review for denial of reconsideration)
Latshaw v. Trainer Wortham & Co., 452 F.3d 1097 (9th Cir. 2006) (Rule 60(b)(6) requires extraordinary circumstances and is used sparingly)
Phelps v. Alameida, 569 F.3d 1120 (9th Cir. 2009) (requiring clear and authoritative change in law to justify reconsideration)
In re Roman Catholic Archbishop of Portland in Or. (Father M v. Various Tort Claimants), 661 F.3d 417 (9th Cir. 2011) (application of good-cause standard in related litigation)
Phillips v. General Motors Corp., 307 F.3d 1206 (9th Cir. 2002) (discussing good-cause balancing standard)
School Dist. No. 1J, Multnomah Cty. v. ACandS, Inc., 5 F.3d 1255 (9th Cir. 1993) (documents available from the beginning cannot support relief on reconsideration)