Turner v. Pleasant
663 F.3d 770
5th Cir.2011Background
- Turners seek to reopen a 2001 judgment in a Louisiana district court.
- District court entered summary judgment for Pleasant, RPIA, and Standard Fire after a bench trial.
- Turners moved for new trial and recusal; court denied, Fifth Circuit affirmed.
- Turners filed an independent action in equity in 2010 asserting fraud on the court and seeking relief from the judgment.
- District court dismissed as barred by res judicata, and Turners appealed.
- Court reverses and remands to allow a merits-based assessment of the independent action.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether res judicata bars an independent equity action. | Turners claim independent-equity relief despite prior judgment. | Res judicata forecloses relitigating claims already raised or could have been raised. | No; res judicata yields where independence and fraud require relief. |
| Whether the complaint plausibly alleges fraud on the court. | House Report and alleged conspiracies show fraud on the court. | Fraud must be pleaded with particularized facts; allegations insufficient. | Plaintiff's allegations plausibly plead fraud on the court under Rule 60(d)(3). |
| Whether Turners were at fault for not uncovering the fraud. | Turners exercised due diligence; discovery impeded by court and counsel. | Turners failed to take possible depositions or other discovery. | Turners not at fault; circumstances plausibly prevented discovery. |
| Whether Turners have an adequate remedy at law. | Rule 60(b) would provide relief for fraud; barring relief is improper. | Remedy at law was available; equity relief not warranted. | No adequate remedy at law; independent-equity relief appropriate. |
Key Cases Cited
- Addington v. Farmer's Elevator Mut. Ins. Co., 650 F.2d 663 (5th Cir. 1981) (five elements of independent action in equity)
- Test Masters Educ. Servs., Inc. v. Singh, 428 F.3d 559 (5th Cir. 2005) (res judicata and final judgments; finality considerations)
- Beggerly, United States v., 524 U.S. 38 (1998) (fraud on the court; Rule 60(d)(3) relief not to be used for routine fraud)
- Procter & Gamble Co. v. Amway Corp., 376 F.3d 496 (5th Cir. 2004) (management of courts; relief from judgment considerations)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading standards; plausibility requirement)
- Ashcroft v. Iqbal, 129 S. Ct. 1937 (2009) (context-specific plausibility interpretation of pleadings)