Plain-English summary
Rule 60(b)(1)’s “mistake” covers judicial legal errors; Kemp’s motion was time-barred
The Court held that Federal Rule of Civil Procedure 60(b)(1)’s word “mistake” includes a district court’s error of law. Because Dexter Kemp’s motion argued such a legal error, it qualified as a Rule 60(b)(1) motion but was barred by the rule’s one-year deadline.
Why this matters
This decision clarifies that parties can use Rule 60(b)(1) to challenge a final judgment based on a court’s legal mistake, but such motions must meet the rule’s strict one-year deadline. That timing rule can bar late challenges even when a judge made an incorrect legal ruling.
Who may feel it
- Civil litigants who seek to reopen final judgments
- Criminal defendants who file postjudgment motions in civil-like procedural contexts (e.g., collateral proceedings)
- Trial and appellate courts evaluating postjudgment relief motions
- Attorneys who litigate Rule 60 motions and related procedural relief
Key questions
- Does Rule 60(b)(1)’s phrase "mistake" include a judge’s error of law?
- If a Rule 60(b)(1) motion alleges a legal error by the court, is it subject to Rule 60(c)’s one-year time limit?