Watson v. Boyd
4:17-cv-02187
E.D. Mo.Jun 13, 2025Background
- Fred Watson brought a civil rights suit under 42 U.S.C. § 1983 against Officer Eddie Boyd III and the City of Ferguson, alleging various constitutional violations arising from a police encounter.
- Watson asserted claims including unlawful search and seizure, retaliatory arrest, retaliatory use of force, malicious prosecution, and municipal liability.
- The district court granted summary judgment to the defendants on all claims. Watson appealed.
- The Eighth Circuit affirmed summary judgment on all claims except the First Amendment retaliatory use-of-force claim, remanding that claim for further proceedings.
- Watson subsequently sought Rule 60(b) relief from the summary judgment on his retaliatory arrest claim, pointing to "newly available" objective arrest data.
- The district court now addresses Watson’s post-appeal motion for relief from judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Rule 60(b)(2) – New Evidence | Objective arrest data is new evidence warranting relief. | Data was available with reasonable diligence and already used. | Data was not "new"; relief under 60(b)(2) denied. |
| Rule 60(b)(6) – Catchall Provision | Evolving law & data availability justify extraordinary relief. | No extraordinary circumstances; argument is a repackaged 60(b)(2). | Law changes are not extraordinary; relief denied. |
| Law Change Exception (Nieves/Gonzalez) | The law shifted; new Supreme Court precedent supports claim. | Law change does not excuse earlier omission of evidence. | Legal change does not justify relief. |
| Mandate Deviation | Requests district court to revisit affirmed judgment. | Case mandate from appellate court should not be disturbed. | Will not deviate from Eighth Circuit mandate. |
Key Cases Cited
- Monell v. Dep’t of Soc. Servs. of City of N.Y., 436 U.S. 658 (municipal liability under § 1983 requires policy or custom)
- Nieves v. Bartlett, 587 U.S. 391 (retaliatory arrest claim generally requires proof of lack of probable cause)
- Gonzalez v. Trevino, 602 U.S. 653 (objective evidence required for exception in retaliatory arrest)
- Kemp v. United States, 596 U.S. 528 (Rule 60(b)(6) only applies when other subsections do not)
- Poletti v. Comm’r of Internal Revenue, 351 F.2d 345 (district court should not deviate from appellate mandate)