Garrett-Graham v. Garrett, 1:25-cv-20769

Plaintiff Angela Garrett-Graham filed a civil suit against David Lee Garrett and various entities, alleging damages as a shareholder due to misappropriation, embezzlement, fraud, and forgery.
Plaintiff sought relief under 18 U.S.C. § 2314 and 18 U.S.C. § 666, both criminal statutes, and claimed the case was dismissed without a hearing.
Plaintiff moved for reconsideration of the dismissal or, in the alternative, for leave to amend her complaint.
The initial complaint did not specify relevant statutes for a civil cause of action or clearly articulate her legal claims for relief.
Plaintiff filed an amended complaint but did not pay the court filing fee or submit a renewed application to proceed in forma pauperis after her previous application was denied as moot.
The court reviewed the motion under Federal Rules of Civil Procedure 59(e) and 60(b), which govern motions to reconsider or alter court judgments.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Entitlement to reconsideration under FRCP 59(e)/60(b)	Dismissal was improper; clarifies intent to use criminal statutes	Not stated	Motion denied; no manifest error or new evidence shown
Right to a hearing before dismissal	Case dismissed without hearing was improper	Not stated	No right to hearing; court discretion is sufficient
Private right of action under criminal statutes	Sought to use 18 U.S.C. § 2314 and § 666 as basis for suit	Not stated	Denied; no private right to sue under these statutes
Leave to amend the complaint	Requested to clarify federal causes of action in amended pleading	Not stated	Granted; plaintiff may amend but must pay fee or reapply

Arthur v. King, 500 F.3d 1335 (11th Cir. 2007) (Rule 59(e) motions can't be used to relitigate old matters or raise new arguments available earlier)
Cano v. Baker, 435 F.3d 1337 (11th Cir. 2006) (Relief under Rule 60(b)(6) requires 'sufficiently extraordinary' circumstances)