Vaughn v. Performance Labs, LLC, 1:24-cv-00138

Plaintiff Tiffany Vaughn filed a lawsuit under 42 U.S.C. § 1983 and state law regarding child custody and visitation, naming both private and state actors as defendants.
The initial complaint was dismissed based on res judicata due to a previously dismissed, similar suit; Vaughn appealed.
The Eighth Circuit reversed and remanded, ruling the earlier dismissal did not bar the action under res judicata and instructing the district court to evaluate if a claim was properly stated.
On remand, Vaughn amended her complaint, but the district court dismissed it again, finding lack of subject matter jurisdiction (domestic relations exception, Rooker-Feldman doctrine) and failure to state a viable § 1983 claim.
Vaughn moved for reconsideration under Rule 59(e) and Rule 60(b), and also requested the judge’s recusal, arguing legal error and judicial bias.
The court now denies both the motion for reconsideration and the recusal request.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether dismissal was procedurally proper	Vaughn: Dismissal was premature, improper, and contrary to precedent	Defendants: Court lacked jurisdiction	Dismissal was proper under jurisdictional doctrines.
Scope of Eighth Circuit remand	Vaughn: Remand required case to proceed on the merits	Defendants: Only required claim evaluation	Remand required only an assessment if claim stated.
Consideration of new evidence in motion to reconsider	Vaughn: New evidence and facts warrant reconsideration	Defendants: New evidence cannot be introduced	Motion cannot be used to present evidence available earlier; denied.
Judicial recusal	Vaughn: Judge biased based on rulings	Defendants: No evidence of bias	No grounds for recusal; adverse decisions not bias.

United States v. Metro. St. Louis Sewer Dist., 440 F.3d 930 (8th Cir. 2006) (standards for granting Rule 59(e) motion to alter or amend judgment)
In re Guidant Corp. Implantable Defibrillators Products Liab. Litig., 496 F.3d 863 (8th Cir. 2007) (Rule 60(b) requires extraordinary circumstances for relief)
Broadway v. Norris, 193 F.3d 987 (8th Cir. 1999) (Rule 60(b) is not for relitigation of merit-based arguments)
A.J. by L.B. v. Kierst, 56 F.3d 849 (8th Cir. 1995) (objective standard for judge recusal)
United States v. Martin, 757 F.3d 776 (8th Cir. 2014) (recusal required if reasonable doubts about impartiality)
Johnson v. Steele, 999 F.3d 584 (8th Cir. 2021) (heavy burden on party requesting judicial disqualification)