Salazar Ex Rel. Salazar v. District of Columbia
394 U.S. App. D.C. 213
| D.C. Cir. | 2011Background
- Salazar challenged a district court dental order under a settlement enforcing EPSDT dental services for Medicaid-eligible children.
- Settlement approved Jan. 22, 1999; Paragraph 36 required provision of EPSDT services when requested.
- Two enforcement motions: (1) 2002 enforcement leading to 2003 order increasing notice, actions, and mailings; (2) 2004 enforcement leading to the 2004 Dental Order with participation targets.
- Monitor reported Jan. 27, 2006 that 80% target was unrealistic and recommended reevaluation.
- District government filed Rule 60(b)(6) motion to vacate May 26, 2006; district court denied Feb. 18, 2010 as untimely and lacking extraordinary circumstances.
- District government appeals arguing the denial was an abuse of discretion and that the court exceeded the settlement by requiring actions not agreed to or mandated by federal law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Rule 60(b)(6) motion was timely. | Salazar argues delay was justified in a long-running reform case. | Salazar contends the motion was untimely. | The motion was timely under the flexible standard in institutional reform cases. |
| Whether the district court exceeded its authority by imposing post-settlement requirements beyond the parties’ agreement. | District argued the Dental Order went beyond the settlement. | District asserted authority to enforce federal standards and modify relief as needed. | No clear error; authority to modify relief under settlement remains within judicial discretion when warranted. |
| Whether extraordinary circumstances justified vacating a prospective relief order. | District claimed extraordinary circumstances due to changed circumstances and monitor’s report. | Appellees argued no extraordinary circumstances or prejudice. | Extraordinary circumstances not shown; rule 60(b)(6) relief affirmed denial. |
| Whether Rule 60(b)(6) relief is a substitute for appeal and should be denied when lack of diligence is shown. | District delayed but engaged in ongoing remediation efforts. | Delay indicates lack of diligence; relief inappropriate. | Gonzalez Ackermann-Liljeberg line governs; lack of diligence precludes relief; in this case relief denied. |
Key Cases Cited
- Hazel-Atlas Glass Co. v. Hartford-Empire Co., 322 U.S. 238 (1944) (final judgments not easily revisited; Rule 60(b) context recognized)
- Klapprott v. United States, 335 U.S. 601 (1949) (extraordinary circumstances; deprivation of defense opportunities; before appeal option matters)
- Ackermann v. United States, 340 U.S. 193 (1950) (duty to appeal; voluntary choices limit Rule 60(b)(6))
- Liljeberg v. Health Servs. Acquisition Corp., 486 U.S. 847 (1988) (requires extraordinary circumstances for Rule 60(b)(6))
- Pioneer Inv. Servs. Co. v. Brunswick Assocs. Ltd. P'ship, 507 U.S. 380 (1993) (time limits under Rule 60(b) and equities in relief)