Skrabec v. Town of North Attleboro, 878 F.3d 5

After being arrested and later acquitted of charges for allegedly threatening to "shoot up" his high school, Patrick Skrabec and his parents sued the Town of North Attleboro and several officers under § 1983 and state tort theories.
The district court set a dispositive-motion schedule requiring oppositions to be filed by November 30, 2016; the Town filed a motion for summary judgment on October 28, 2016.
The Skrabecs’ counsel exchanged settlement-related e-mails with the Town’s counsel in late October–November but did not obtain an agreed extension or inform the court; Patrick died on October 20, 2016.
The Skrabecs did not file an opposition; the district court entered summary judgment for the Town as unopposed on December 28, 2016.
Two days later the Skrabecs moved under Fed. R. Civ. P. 60(b)(1) for relief from judgment for "excusable neglect," arguing their counsel reasonably believed settlement discussions negated the need to respond; the district court denied relief.
On appeal, the First Circuit affirmed, holding counsel’s assumption was unsupported and that the Pioneer factors did not show excusable neglect.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rule 60(b)(1) relief for excusable neglect was warranted after failing to oppose summary judgment	Skrabec: counsel reasonably believed ongoing settlement discussions excused or obviated the need to file opposition	Town: no agreement to extend deadline; counsel’s assumption was unilateral and unjustified	Denied — no excusable neglect; counsel’s assumption insufficient
Whether the death of Patrick justified treating counsel’s omission as excusable	Skrabec: Patrick’s death disrupted negotiations and case preparation	Town: death did not create an agreement to extend deadlines or excuse filings	Denied — death did not explain or justify the specific procedural lapse
Whether the district court abused its discretion in applying Pioneer factors	Skrabec: trial court should have granted relief under equitable considerations	Town: district court properly weighed Pioneer factors and discretion	Affirmed — no abuse of discretion; reason for omission decisive
Whether counsel’s negligence can be imputed to clients for Rule 60(b)(1) purposes	Skrabec: urged equitable relief despite counsel’s mistake	Town: clients accountable for counsel’s omissions	Affirmed — attorney negligence imputed; clients not entitled to relief

Pioneer Inv. Servs. Co. v. Brunswick Assocs. Ltd. P'ship, 507 U.S. 380 (sets equitable four-factor test for excusable neglect)
Nansamba v. N. Shore Med. Ctr., Inc., 727 F.3d 33 (explains excusable-neglect standard and importance of reason for oversight)
Dávila-Álvarez v. Escuela de Medicina Universidad Cent. del Caribe, 257 F.3d 58 (Rule 60(b) relief is for exceptional circumstances)
Karak v. Bursaw Oil Corp., 288 F.3d 15 (elements required for Rule 60(b) relief)
Dimmitt v. Ockenfels, 407 F.3d 21 (attorney’s unexplained omission not excusable neglect)
de la Torre v. Cont'l Ins. Co., 15 F.3d 12 (settlement negotiations do not excuse missed court filings)