Raymond Alves v. Merrill Main
687 F. App'x 218
| 3rd Cir. | 2017Background
- This appeal arises from a class-action settlement concerning mental-health treatment at New Jersey’s Special Treatment Unit for sexually violent predators.
- Joseph Aruanno filed a "Motion to Reopen/Reinstate" (Sept. 21, 2014) and a motion seeking appointment of a legal guardian; the reopen motion listed ten grievances about his treatment and conditions.
- The District Court construed the motion as one under Federal Rule of Civil Procedure 60(b)(6) and denied both the motion to reopen and the guardian appointment; Aruanno appealed.
- The Third Circuit reviewed the denial of Rule 60(b) relief for abuse of discretion and considered whether Aruanno’s allegations amounted to the "extraordinary circumstances" required for relief under Rule 60(b)(6).
- Aruanno’s complaints included lack of one-on-one therapy or a specific therapist, noise complaints, not receiving a trivia prize, and not being given a snack; the court found these did not meet the extraordinary-circumstances standard.
- The court also found no basis to appoint a guardian: prior proceedings showed no evidence of legal incompetence, Aruanno offered no new evidence, and no ADA right to appointed counsel exists.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court abused discretion by denying a Rule 60(b) motion to reopen settlement | Aruanno argued the case should be reopened based on listed post-settlement grievances about treatment and conditions | The settlement was final; Aruanno’s grievances are not "extraordinary circumstances" warranting Rule 60(b)(6) relief | Denial affirmed — grievances do not constitute extraordinary circumstances for Rule 60(b)(6) relief |
| Whether the district court erred by not appointing a legal guardian | Aruanno claimed incompetence and requested a guardian to represent him | Defendants (and court) noted prior findings of competency and absence of new evidence showing incompetence; no statutory right to appointed counsel under ADA | Denial affirmed — no new evidence of incompetence; appointment not required |
Key Cases Cited
- Buck v. Davis, 137 S. Ct. 759 (U.S. 2017) (describing "extraordinary circumstances" standard for Rule 60(b)(6))
- Budget Blinds, Inc. v. White, 536 F.3d 244 (3d Cir. 2008) (standard of review: abuse of discretion for Rule 60(b) denials)
- Norris v. Brooks, 794 F.3d 401 (3d Cir. 2015) (Rule 60(b)(6) relief reserved for extraordinary circumstances to avoid extreme hardship)
- Tabron v. Grace, 6 F.3d 147 (3d Cir. 1993) (standard for denial of appointment of counsel reviewed for abuse of discretion)
- Aruanno v. Davis, 168 F. Supp. 3d 719 (D.N.J. 2016) (prior finding showing no evidence of legal incompetence)