884 F.3d 546
5th Cir.2018Background
- In 1993 Louisiana enacted a "2-3" judicial-districting plan for Baton Rouge: two election sections subdivided into five divisions (two majority-black seats B & D; three majority-white seats A, C & E).
- Demographics shifted such that Baton Rouge became majority-black; Hall sued alleging the "2-3" plan violated Section 2 of the Voting Rights Act and the Fourteenth and Fifteenth Amendments; Sharper intervened.
- After a bench trial the district court rejected Hall's claims and entered final judgment against him.
- Two days after the judgment, the Louisiana Legislature enacted Act 374 (House Bill 76), converting the system to a "2-2-1" plan; the governor signed it before Hall’s appeal period expired, mooting his claims for declaratory and injunctive relief.
- Hall moved under Fed. R. Civ. P. 60(b)(6) to vacate the district court’s judgment as to the now-moot Section 2 claim to preserve the ability to relitigate; the district court denied relief balancing fault and public interest.
- The Fifth Circuit affirmed, holding the district court did not abuse its discretion in denying vacatur under Rule 60(b)(6).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether district court abused discretion denying Rule 60(b)(6) vacatur of judgment mooted by intervening legislation | Hall: vacatur required where mootness was caused by circumstances beyond his control; equity favors vacatur to permit future relitigation | Government: vacatur is not automatic; court should weigh equities including public interest and precedent; no abuse of discretion | Affirmed: district court properly exercised discretion—fault/public-interest balance did not compel vacatur |
| Whether appellate vacatur precedent (Munsingwear/Bancorp) controls district courts deciding Rule 60(b)(6) vacatur | Hall: relied on cases vacating judgments when appeals became moot | Government: those decisions govern appellate §2106 motions, not Rule 60(b)(6) motions | Court: Bancorp/Munsingwear inform but do not bind district courts; fault and public-interest factors are largely determinative for Rule 60(b)(6) too |
| Whether legislative action by a nonparty state legislature should be treated as fault for mooting an appeal | Hall: key equitable inquiry is whether movant caused loss of appeal rights; legislature’s action was beyond Hall’s control so favors vacatur | Government: legislature is nonparty; no fault by defendants; public interest in preserving precedent weighs against vacatur | Held: legislature’s action attributed to state acts in unity; no fault by Hall or defendants; district court reasonably denied vacatur |
| Whether vacatur should be granted to avoid res judicata effect on a now-defunct state election law | Hall: vacatur needed to clear the path for future relitigation of the law | Government: limited effect on nonparties and public interest in stable precedent counsels against vacatur | Held: district court did not abuse discretion; preserving precedent outweighed equities favoring vacatur |
Key Cases Cited
- U.S. Bancorp Mortg. Co. v. Bonner Mall P'ship, 513 U.S. 18 (1994) (articulates limits on vacatur when mootness results from settlement and emphasizes equitable fault/public-interest inquiry)
- United States v. Munsingwear, Inc., 340 U.S. 36 (1950) (endorses vacatur to avoid preclusive effect when mootness prevents appellate review)
- Staley v. Harris Cty., Tex., 485 F.3d 305 (5th Cir. 2007) (en banc) (applies Bancorp principles and directs case-by-case equitable analysis for vacatur)