Harris v. Greater Erie County Action Committee
671 F. App'x 853
| 3rd Cir. | 2016Background
- Corey L. Harris sued multiple defendants in 2004 alleging they stole trade secrets and copied his plan for a transportation service; the District Court dismissed the amended complaint in 2006.
- Harris filed successive Rule 60(b) motions (first in 2012 and others later) seeking to reopen the 2006 judgment; earlier motions were denied.
- In 2015 Harris filed a fourth Rule 60(b) motion asserting newly discovered evidence and judicial conflict: that Judge McLaughlin owned stock in an insurer allegedly insuring Harris’ competitor (Uber).
- The District Court questioned the plausibility of the conflict (noting Uber postdated the 2006 dismissal) and denied the Rule 60(b) motion as untimely; Harris timely moved for reconsideration under Rule 59(e), which was denied.
- Harris appealed; he also asserted broader claims about inventing Uber and trademark infringement, but the appeal focused on the timeliness and reasonableness of the Rule 60(b) motion and the Rule 59(e) motion for reconsideration.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rule 60(b)(2) relief for newly discovered evidence is available | Harris: new evidence (discovered after a long investigation) justifies reopening judgment | District Court/defendants: Rule 60(b)(2) claims are subject to a one-year limit and Harris’ motion was filed long after that period | Denied — (60(b)(2) untimely; must be within one year) |
| Whether Rule 60(b)(6) extraordinary-circumstances relief applies despite delay | Harris: extraordinary circumstances justify relief despite delay | District Court/defendants: no extraordinary circumstances and the nine-year delay is unreasonable without adequate explanation | Denied — no extraordinary circumstances; motion not filed within a "reasonable time" |
| Whether the district judge’s alleged financial interest required recusal and invalidates the prior judgment | Harris: judge had a conflict (stock in insurer covering competitor) that required recusal | District Court/defendants: allegations implausible and untimely; do not excuse delay | Rejected — allegations implausible and do not cure untimeliness or meet Rule 60 standards |
| Whether the Rule 59(e) motion for reconsideration warranted relief | Harris: sought reconsideration of denial | District Court/defendants: Harris failed to show intervening law, new evidence, or clear error | Denied — did not meet standards for Rule 59(e) reconsideration |
Key Cases Cited
- Reform Party of Allegheny County v. Allegheny County Dep’t of Elections, 174 F.3d 305 (3d Cir. 1999) (standard of review for Rule 60(b) denial)
- Boughner v. Secretary of Health, Education & Welfare, 572 F.2d 976 (3d Cir. 1978) (Rule 60 purpose: balance finality and justice)
- Martinez-McBean v. Gov’t of Virgin Islands, 562 F.2d 908 (3d Cir. 1977) (Rule 60(b)(6) extraordinary-circumstances standard and timeliness)
- Moolenaar v. Gov’t of Virgin Islands, 822 F.2d 1342 (3d Cir. 1987) (delay of two years held unreasonable for Rule 60(b)(6))
- Max’s Seafood Café v. Quinteros, 176 F.3d 669 (3d Cir. 1999) (standards for granting a Rule 59(e) motion for reconsideration)
- Lizardo v. United States, 619 F.3d 273 (3d Cir. 2010) (tolling of appeal period when Rule 59(e) motion timely filed)