908 F.3d 365
8th Cir.2018Background
- Giles sued Saint Luke’s for hostile work environment, retaliation, and discrimination (race, color, age). Discovery closed April 6, 2017; dispositive motions due May 5, 2017.
- Saint Luke’s filed a summary judgment motion on May 5; Giles’s response was due May 26 but was not filed on time.
- Nine days late (June 4), Giles moved for an extension until June 30, citing other depositions, counsel’s briefing deadline, and personal travel; the district court denied the extension and—treating the summary-judgment motion as unopposed—entered judgment for Saint Luke’s.
- Giles moved for reconsideration (construed as a Rule 60(b) motion) alleging excusable neglect based on counsel’s scheduling conflicts and depositions; the district court denied relief.
- The Eighth Circuit reviewed only the Rule 60(b) denial for abuse of discretion; Giles did not appeal the substantive grant of summary judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court abused its discretion denying relief under Rule 60(b)(1) for excusable neglect | Giles: counsel’s scheduling conflicts, ongoing depositions, and travel justify relief and an extension to oppose summary judgment | Saint Luke’s: delay was counsel’s fault, no basis for excusable neglect, and no meritorious defense shown | Denied — district court did not abuse discretion: Pioneer factors weigh against relief because delay resulted from counsel’s carelessness and no meritorious defense was offered |
| Whether relief is warranted under Rule 60(b)(6) for "exceptional circumstances" | Giles: exceptional circumstances justify relief under Rule 60(b)(6) | Saint Luke’s: no exceptional circumstances; counsel’s carelessness is insufficient | Waived and in any event denied — attorney incompetence/carelessness is not grounds for Rule 60(b)(6) relief |
Key Cases Cited
- Pioneer Inv. Servs. Co. v. Brunswick Assocs. Ltd. P’ship, 507 U.S. 380 (framework for excusable neglect analysis)
- In re Guidant Corp. Implantable Defibrillators Prods. Liab. Litig., 496 F.3d 863 (applying Pioneer factors in the Eighth Circuit)
- Feeney v. AT & E, Inc., 472 F.3d 560 (meritorious-defense factor is relevant to Rule 60(b)(1))
- Noah v. Bond Cold Storage, 408 F.3d 1043 (attorney ignorance/carelessness not excusable neglect)
- Inman v. Am. Home Furniture Placement, Inc., 120 F.3d 117 (Rule 60(b)(6) exceptional-circumstances standard)
- Int’l Bhd. of Elec. Workers v. Hope Elec. Corp., 293 F.3d 409 (rare reversal of Rule 60(b) denials)
- Interstate Power Co. v. Kan. City Power & Light Co., 992 F.2d 804 (district court must independently determine entitlement when summary judgment is unopposed)
- Atkinson v. Prudential Prop. Co., 43 F.3d 367 (Rule 60(b)(6) principles)
- Sutherland v. ITT Cont’l Baking Co., 710 F.2d 473 (attorney incompetence/carelessness not a basis for 60(b)(6) relief)