Mindy Zied v. Barnhart, 15-2821

Pro se plaintiff Mindy Zied previously filed suits challenging an ALJ decision on her SSI benefits and asserting various constitutional and statutory claims against the Social Security Administration and employees. The district court directed separate actions for the benefits claim and for other claims.
Zied’s non-benefits action was dismissed by the district court as time-barred; this Court affirmed that dismissal in 2011.
On June 24, 2015, more than four years after this Court’s judgment, Zied filed a 227‑page Rule 60 motion to reopen and to amend her complaint, reasserting a mix of long‑running grievances including SSI entitlement and numerous constitutional/statutory challenges.
The district court denied the post‑judgment motion and refused leave to amend; Zied appealed and the Third Circuit reviewed for abuse of discretion.
The Third Circuit concluded Zied’s Rule 60(b) motion was untimely under subsections (1)–(3) and (5)–(6), she did not invoke a proper Rule 60(b)(4) defect, she failed to show extraordinary circumstances under 60(b)(6), and the court properly denied leave to amend for undue delay, improper re-litigation of benefits issues, and failure to state a plausible claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Zied’s Rule 60 motion was timely	Zied sought relief reopening the judgment and amending her complaint >4 years after judgment	District court argued Rule 60 deadlines and reasonable‑time standard bar the motion	Motion untimely under Rule 60(b)(1)–(3) and not within a reasonable time for (5)–(6)
Whether relief is available under Rule 60(b)(4) (void judgments)	Implied challenge to prior proceedings	Defendants: judgment was not void; no jurisdictional defect shown	No claim of void judgment; Rule 60(b)(4) inapplicable
Whether extraordinary circumstances justify relief under Rule 60(b)(6)	Zied alleged longstanding hardships and pervasive wrongs	Defendants: no extraordinary, unexpected hardship warranting relief	No extraordinary circumstances shown; 60(b)(6) relief denied
Whether district court abused discretion in denying leave to amend	Zied sought to add many allegations and revive benefits claims	Defendants: undue delay, earlier availability of claims, and prior mandate separating benefits claims	Denial affirmed: undue delay, improper attempt to relitigate benefits, and failure to plead plausible claims

Ahmed v. Dragovich, 297 F.3d 201 (3d Cir. 2002) (standard of review for Rule 60 motions and abuse of discretion review)
Moolenaar v. Gov’t of the V.I., 822 F.2d 1342 (3d Cir. 1987) (delay can render a Rule 60(b)(6) motion untimely)
United States v. One Toshiba Color TV, 213 F.3d 147 (3d Cir. 2000) (en banc) (Rule 60(b)(4) relief for void judgments not subject to one‑year limit)
Marshall v. Bd. of Educ., 575 F.2d 417 (3d Cir. 1978) (definition of void decree under Rule 60(b)(4))
United States v. Walker, 109 U.S. 258 (1883) (historical articulation of void judgments concept)
Cox v. Horn, 757 F.3d 113 (3d Cir. 2014) (Rule 60(b)(6) requires extraordinary circumstances)
Sawka v. Healtheast, Inc., 989 F.2d 138 (3d Cir. 1993) (same standard for 60(b)(6))
Burtch v. Milberg Factors, Inc., 662 F.3d 212 (3d Cir. 2011) (standards for post‑judgment amendment)
Cureton v. Nat’l Collegiate Athletic Ass’n, 252 F.3d 267 (3d Cir. 2001) (undue delay justifies denial of leave to amend)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility standard for pleading)
In re Fine Paper Antitrust Litig., 685 F.2d 810 (3d Cir. 1982) (procedural matters regarding filing restrictions and related relief)