Jones v. U.S. Department of Education
693 F. App'x 107
| 3rd Cir. | 2017Background
- Michael Jones, a blind plaintiff, sued under the Randolph‑Sheppard Act to review a DOE arbitration panel decision; the case settled in Dec. 2015 for significant monetary and debt‑forgiveness benefits and was dismissed with prejudice in Oct. 2015, with the magistrate retaining jurisdiction to enforce the settlement.
- Jones later, pro se, asserted duress, lack of a Braille copy, and an alleged defendant breach, prompting the magistrate to hold a telephone conference to assess his claims and demeanor.
- At the conference the magistrate found Jones had time to consult family and three competent attorneys who advised him, that he received substantial benefits ($365,000 plus debt relief), and that the defendant had complied with the agreement; the magistrate denied Jones’s request to revoke the settlement as frivolous.
- Jones appealed the magistrate’s order to the Third Circuit, which dismissed for lack of jurisdiction because he had not appealed to the district court first; he then moved in district court under Rule 60(b) to vacate the settlement and offered to return settlement funds.
- The district court denied Rule 60(b) relief, accepting the magistrate’s findings that Jones knowingly and voluntarily entered the settlement and that no evidentiary hearing was required; Jones timely appealed and the Third Circuit summarily affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the settlement should be vacated for duress or lack of accommodation (Braille) | Jones: he signed under duress and wasn’t provided a Braille copy | Defendants/Magistrate: Jones had time, counsel, and knowingly accepted substantial benefits | Court: No — findings that agreement was knowing and voluntary upheld |
| Whether the magistrate’s post‑settlement order was immediately appealable | Jones: appealed magistrate’s denial directly to Third Circuit | Defendants: must first seek district court review | Court: Dismissed earlier appeal for lack of jurisdiction; proper route is district court review |
| Whether Rule 60(b) relief was warranted | Jones: asked district court to vacate settlement and offered to return funds | Defendants: motion is meritless given prior findings and compliance | Court: Denied — no abuse of discretion in rejecting Rule 60(b) motion |
| Whether an evidentiary hearing was required before denying relief | Jones: requested hearing to present unspecified evidence | Defendants: magistrate’s conference and record sufficed | Court: No hearing necessary; Jones did not show what evidence would be produced |
Key Cases Cited
- Brown v. Philadelphia Housing Authority, 350 F.3d 338 (3d Cir.) (standard of review for Rule 60(b) denial)
- Reform Party of Allegheny County v. Allegheny County Dep't of Elections, 174 F.3d 305 (3d Cir. en banc) (defines abuse of discretion standard)
- Kokkonen v. Guardian Life Insurance Co. of America, 511 U.S. 375 (U.S. 1994) (federal courts’ jurisdiction to enforce settlement agreements and retained jurisdiction language)
- Raab v. City of Ocean City, N.J., 833 F.3d 286 (3d Cir.) (district court jurisdiction to enforce settlement when dismissal retains jurisdiction)
- McDowell v. Philadelphia Housing Authority, 423 F.3d 233 (3d Cir.) (district court discretion on whether to hold evidentiary hearing)