Reggie White v. National Football League, 756 F.3d 585

The White class action (filed 1992; certified 1993) challenged various NFL practices; parties instead executed a comprehensive Stipulation and Settlement Agreement (SSA) in 1993 that functioned largely as a collective bargaining agreement and was extended multiple times.
Article XI of the SSA required the final league year to be uncapped (2010); players expected a salary surge in 2010 that did not occur, leading to a collusion allegation that the NFL secretly imposed a cap.
In 2011 the NFL and the NFLPA negotiated a new CBA and the Association executed a stipulated dismissal (Rule 41(a)(1)(A)(ii)) in the White docket that broadly released "all claims, known and unknown . . . regarding the SSA including . . . collusion with respect to the 2010 League Year."
After public statements by owners and the Commissioner suggested 2010 collusion, the Association sought to reopen the claim, arguing (1) the Dismissal was invalid because settling class claims requires court approval under Rule 23(e), and (2) alternatively the Dismissal should be set aside under Rule 60(b)(3) as procured by fraud/misconduct.
The district court denied both grounds; the Eighth Circuit affirmed the Rule 23(e) ruling (Dismissal not settling claims "of a certified class") but reversed the Rule 60(b) jurisdictional ruling, holding a stipulated dismissal can be attacked under Rule 60(b).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rule 23(e) court approval was required to dismiss the collusion claim	Association: the Dismissal settled a claim arising from the class settlement (SSA) and so required Rule 23(e) approval	NFL: the 2010 collusion claim was distinct from the certified White class claims and the SSA is not a typical class settlement subject to Rule 23(e)	Held: Rule 23(e) did not apply — the 2010 claim was not a claim "of a certified class" and the SSA functioned largely as a standalone CBA rather than a bargained-for class settlement
Whether a party who stipulates to dismissal under Rule 41(a)(1)(A)(ii) may seek relief under Rule 60(b)	Association: even stipulated dismissals should be subject to Rule 60(b) when procured by fraud; otherwise fraud could escape review	NFL: prior Eighth Cir. unpublished decisions suggested Rule 60(b) relief unavailable for stipulated dismissals	Held: Reversed district court — a Rule 41(a)(1)(A)(ii) stipulated dismissal qualifies as a "judgment, order, or proceeding" under Rule 60(b), so the Association may seek relief (though Rule 60(b) relief remains extraordinary and burdensome to obtain)

Am. Needle v. Nat’l Football League, 560 U.S. 183 (explains NFL's statutory antitrust status and Rule of Reason deference)
White v. Nat’l Football League, 822 F. Supp. 1389 (D. Minn. 1993) (original class action and SSA context)
Mackey v. Nat’l Football League, 543 F.2d 606 (8th Cir. 1976) (prior antitrust challenge to NFL labor rule)
Randall v. Merrill Lynch, 820 F.2d 1317 (D.C. Cir. 1987) (held a voluntary dismissal can be a final judgment for Rule 60(b))
Yesh Music v. Lakewood Church, 727 F.3d 356 (5th Cir. 2013) (circuit precedent holding stipulated dismissals are subject to Rule 60(b) review)