In Re Black Farmers Discrimination Litigation
950 F. Supp. 2d 196
D.D.C.2013Background
- Plaintiffs move to modify the final Order and Judgment to supplement the Settlement Agreement to address two groups of allegedly misclassified claims.
- Group 1 received deficiency notices, was given 30 days to cure, but later received letters suggesting no further action was needed, creating confusion.
- Group 2 consisted of claim forms deemed incomplete due to blanks; later review indicated all necessary information was provided, though not in the designated places.
- In total 264 claimants could be adjudicated on the merits if the settlement were amended as requested.
- Any modification would alter the Settlement Agreement's V.B.2 and V.A.8 provisions, raising finality and unreviewability concerns.
- The government opposed the current motion, though it previously did not oppose two earlier, similar requests.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rule 60(b) permits modification of a consent decree despite finality. | Seek relief under Rule 60(b)(5)/(6) to revisit determinations. | Settlement terms are bargained and final; Rule 60(b) cannot override them without consent. | Denied |
| Whether changed circumstances justify modification under Rufo. | Changed circumstances (confusion and misplacements) render compliance unworkable. | No significantly changed circumstances; terms were anticipated and bargained. | Denied |
| Whether modification would amend the Settlement Agreement's finality provisions (V.A.8, V.B.2). | Amendment warranted to adjudicate otherwise eligible claims. | Would contravene explicit finality and non-reviewability terms. | Denied |
Key Cases Cited
- Rufo v. Inmates of Suffolk County Jail, 502 U.S. 367 (1992) (changed circumstances may justify modification of consent decrees)
- Pigford v. Veneman, 292 F.3d 918 (D.C. Cir. 2002) (rule 60(b) modification principles for consent decrees)
- Pigford v. Johanns, 416 F.3d 12 (D.C. Cir. 2005) (requirement of changed circumstances for 60(b) relief)
- Kokkonen v. Guardian Life Insurance Co. of America, 511 U.S. 375 (1994) (settlement enforcement constrained by the decree's terms)