Williams v. Loudon County Sheriff's Department
3:24-cv-00023
E.D. Tenn.Apr 14, 2025Background
- Travis B. Williams filed a pro se complaint against the Loudon County Sheriff’s Department and Jimmy Davis in the Eastern District of Tennessee.
- Williams was granted leave to proceed in forma pauperis, but Magistrate Judge Poplin recommended dismissal for failure to state a claim and as frivolous.
- The District Court adopted the recommendation, dismissed the complaint, and closed the case after finding Williams' objections merely restated the original allegations.
- Williams appealed, but the Sixth Circuit affirmed the dismissal.
- Williams now seeks relief from judgment under Rule 60(b), claiming newly discovered evidence and imminent danger.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Rule 60(b) relief based on new evidence | Williams asserts new evidence warrants reopening the case due to ongoing harm. | No material new evidence; public policy favors finality. | Motion denied; requirements for Rule 60(b) not satisfied. |
| Materiality and due diligence of evidence | Claims evidence (e.g., medical, witness statements) shows harm and abuse. | Evidence not material, cumulative or timely; lacks due diligence. | Evidence insufficient and not qualifying as 'newly discovered.' |
| Timeliness of new evidence | Asserts evidence arose after judgment, necessitating relief. | Evidence postdates judgment and cannot be considered 'newly discovered.' | Rule 60(b)(2) does not allow evidence arising after judgment. |
| Potential for different outcome | Suggests evidence would have changed the result. | Evidence would not lead to a different outcome. | No showing that proffered evidence would alter the judgment. |
Key Cases Cited
- Blue Diamond Coal Co. v. Trs. of UMWA Combined Ben. Fund, 249 F.3d 519 (6th Cir. 2001) (Rule 60(b) relief is limited and judgment finality is favored)
- Info-Hold, Inc. v. Sound Merch., Inc., 538 F.3d 448 (6th Cir. 2008) (Burden of clear and convincing evidence for Rule 60(b) relief)
- Luna v. Bell, 887 F.3d 290 (6th Cir. 2018) (New evidence under Rule 60(b) must be material and could affect the outcome)
- Good v. Ohio Edison Co., 149 F.3d 413 (6th Cir. 1998) (New evidence must not be cumulative or merely impeaching)
- Davis v. Jellico Cmty. Hosp., Inc., 912 F.2d 129 (6th Cir. 1990) (New evidence under Rule 60(b) must have existed at time of judgment)