(PS) Roberts v. Sacramento Housing & Redevelopment Agency
2:22-cv-01699
E.D. Cal.May 19, 2025Background
- Plaintiffs Sydney Brooke Roberts and David Tyrone Samuel filed a motion for relief from the court’s February 28, 2025 order, which denied their motion for summary judgment.
- Plaintiffs proceeded pro se against the Sacramento Housing & Redevelopment Agency and others.
- The denial of summary judgment was based on the existence of disputed material facts and insufficient evidence from the plaintiffs.
- Plaintiffs sought relief under Fed. R. Civ. P. 60(b), but the court noted such relief only applies to final judgments, not interlocutory orders like the denial of summary judgment.
- The court decided to treat the motion as one for reconsideration under Rule 54(b) instead of dismissing it outright.
- After reviewing the arguments, the court found no new evidence, law, or clear error justifying reconsideration and recommended denial of the motion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Applicability of Rule 60(b) | Relief from denial of summary judgment appropriate | Relief not permitted under Rule 60(b) for non-final orders | Rule 60(b) does not apply; motion construed as reconsideration |
| Basis for Reconsideration | Court’s prior analysis was incorrect | No new evidence or law; prior ruling correct | No new facts, law changes, or errors; motion denied |
| Sufficiency of Plaintiffs’ Evidence | Plaintiffs entitled to summary judgment | Material facts remain disputed; insufficient evidence from plaintiffs | Denial appropriate due to fact disputes and insufficient evidence |
| Appropriateness of Relitigation | Ruling should be reconsidered due to alleged errors | Motion merely re-argues previously decided issues | Reconsideration not warranted; motion denied |
Key Cases Cited
- Nat’l Wildlife Fed’n v. Nat’l Marine Fisheries Serv., 886 F.3d 803 (9th Cir. 2018) (defines final orders subject to Rule 60(b))
- City of Los Angeles v. Santa Monica BayKeeper, 254 F.3d 882 (9th Cir. 2001) (district court’s power to reconsider interlocutory orders derived from common law)
- School Dist. No. 1J Multnomah County v. AC & S Inc., 5 F.3d 1255 (9th Cir. 1993) (standard for granting motions for reconsideration)
- Turner v. Duncan, 158 F.3d 449 (9th Cir. 1998) (discussing waiver of appellate rights by failing to object to findings)