Koch v. White, Civil Action No. 2012-1934

Plaintiff Randolph S. Koch, proceeding pro se, moved under Rule 59(e) to alter or amend the court’s May 2, 2017 summary-judgment ruling that favored Jay Clayton in his official capacity as SEC Chair.
Koch argued discovery was unreasonably curtailed in prior MSPB and district-court proceedings and claimed manifest injustice due to (he says) destroyed evidence, a misleading motion about his FOIA activity, and unethical conduct by the defendant.
Koch also asserted the court’s discovery scheduling and enforcement was unfair given his disabilities, bankruptcy, and participation in other litigation.
The court treated Koch’s filing as a Rule 59(e) motion because the May 2 order resolved all claims and parties; Rule 59(e) relief requires an intervening change in law, new evidence, or correction of clear error to prevent manifest injustice.
The court found no intervening change in law, no newly available evidence (three of four exhibits were previously available), and no clear error or manifest injustice warranting amendment of the judgment.
The court denied Koch’s motion, confirming prior consideration and rejection of his spoliation theory and noting the court had granted multiple extensions in light of Koch’s circumstances.

Issue	Plaintiff's Argument	Defendant's Argument / Court's View	Held
Whether Rule 59(e) relief is warranted	Koch: Judgment should be altered due to curtailed discovery and manifest injustice	Court: No intervening law, no new evidence, no clear error	Denied — Rule 59(e) relief not shown
Spoliation / destroyed evidence	Koch: Defendant destroyed records needed to prove his case	Court: Spoliation claim was previously raised and rejected; record lacks support	Denied — cannot relitigate spoliation via Rule 59(e)
New evidence proffered with motion	Koch: Attached exhibits (incl. recent email) support relief	Court: Three exhibits predate the ruling; the recent email is irrelevant to the May 2 decision	Denied — evidence not newly available or material
Procedural fairness re: discovery deadlines	Koch: Deadlines too short given disabilities, bankruptcy, other obligations	Court: Plaintiff must follow Federal Rules; court granted multiple extensions already	Denied — no manifest injustice from scheduling decisions

Firestone v. Firestone, 76 F.3d 1205 (D.C. Cir. 1996) (standards for Rule 59(e) relief: intervening change in law, new evidence, or clear error to avoid manifest injustice)
Idrogo v. Foxx, 990 F. Supp. 2d 5 (D.D.C. 2013) (pro se litigants remain bound by procedural rules and deadlines)
Loumiet v. United States, 65 F. Supp. 3d 19 (D.D.C. 2014) (distinguishing applicability of Rules 54(b) and 59(e) where court resolved all claims)