Gary Rhines v. United States
677 F. App'x 34
| 3rd Cir. | 2017Background
- Pro se federal prisoner Gary Rhines alleged food poisoning at USP Canaan and sued under the Federal Tort Claims Act for negligence, seeking damages and injunctive relief.
- The United States conceded liability after discovery; only damages remained for the bench trial.
- The district court awarded Rhines $3,000 for pain and suffering.
- Twenty-nine days after judgment, Rhines moved under Fed. R. Civ. P. 59(e) to amend the judgment and to add new evidence (including a news article about prisoners being served pet food) and sought leave to amend his complaint to assert willful negligence.
- The district court denied the Rule 59(e) motion, denied leave to amend the complaint, and denied supplementation of the Rule 59(e) motion as futile. Rhines appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court abused discretion in denying Rhines’s Rule 59(e) motion to alter/amend judgment | Rhines sought to add new evidence and legal theories (including medical-malpractice/willful negligence claims and a news article) to increase damages | District court: motion was untimely, did not show intervening change in law, new evidence, or clear error/manifest injustice; new arguments cannot be raised in a Rule 59(e) motion | Affirmed — no abuse of discretion; Rhines did not meet Rule 59(e) standards and some evidence was not new or was unrelated |
| Whether leave to amend complaint post-judgment should be granted | Rhines sought leave to amend to plead willful negligence based on the article and new facts | Defendants: once judgment entered, amendment requires vacatur under Rules 59 or 60; amendment was untimely and improper | Affirmed — denying leave was proper because judgment stood and Rhines did not set it aside |
| Whether supplementation of the Rule 59(e) motion with the news article was permissible | Rhines argued the article constituted newly discovered evidence relevant to damages/willfulness | Defendants: Rule 59 may not be used to raise new arguments/evidence that could have been presented before judgment | Affirmed — supplementation denied as futile and improper use of Rule 59(e) |
| Scope of appellate review and whether summary affirmance is appropriate | Rhines contested factual and legal rulings below | Government relied on deferential abuse-of-discretion standard and asserted no substantial question of law | Court summarily affirmed under local rules — appeal did not present a substantial question of law |
Key Cases Cited
- Howard Hess Dental Labs., Inc. v. Dentsply Int’l., Inc., 602 F.3d 237 (3d Cir. 2010) (standards for reviewing motions for reconsideration and abuse-of-discretion review)
- U.S. ex rel. Schumann v. Astrazeneca Pharma. L.P., 769 F.3d 837 (3d Cir. 2014) (grounds for Rule 59(e) relief: intervening law, new evidence, clear error/manifest injustice)
- Lizardo v. United States, 619 F.3d 273 (3d Cir. 2010) (limits on appeal scope where Rule 59 motion issues control review)
- Ahmed v. Dragovich, 297 F.3d 201 (3d Cir. 2002) (post-judgment amendment of complaint generally disallowed unless judgment is set aside)
- Max’s Seafood Café ex. rel. Lou-Ann, Inc. v. Quinteros, 176 F.3d 669 (3d Cir. 1999) (Rule 59 cannot be used to raise new arguments that should have been presented before judgment)