The question
Whether a case voluntarily dismissed without prejudice under Federal Rule of Civil Procedure 41(a) counts as a "final proceeding" that may be reopened under Rule 60(b).
Waetzig v. Halliburton Energy Services, Inc.
What the Court decided
The Court reversed the Tenth Circuit and held that a case voluntarily dismissed without prejudice under Rule 41(a) counts as a "final proceeding" under Rule 60(b). A voluntary dismissal is "final" because it terminates the case, and a "proceeding" encompasses all formal steps in an action, so a plaintiff may invoke Rule 60(b) to seek relief from such a dismissal. The Court did not reach Halliburton's argument about jurisdiction over the motion to vacate the arbitration award, leaving that for the lower courts on remand.
How the justices split
UnanimousThe Court's opinion
Alito, joined by Roberts, Thomas, Sotomayor, Kagan, Gorsuch, Kavanaugh, Barrett, Jackson
Text, context, and history show that a Rule 41(a) voluntary dismissal without prejudice qualifies as a final proceeding under Rule 60(b). The dismissal is final because it terminates the case, a reading confirmed by 1946 legal dictionaries and the Advisory Committee Notes to the 1946 Amendment. The finality concept in appellate jurisdiction statutes like 28 U.S.C. Section 1291 serves a distinct purpose and is not imported into Rule 60(b), which is discretionary rather than a matter of statutory right. A voluntary dismissal is also a proceeding because that term encompasses all formal steps in an action's progression. The Court did not address the jurisdictional argument about the motion to vacate, leaving it for the lower courts on remand.
How we know · 5 sourced claims
A case voluntarily dismissed without prejudice under Rule 41(a) counts as a final proceeding under Rule 60(b).
Source: syllabus, Held
The Tenth Circuit had reversed the District Court, which reopened the case.
Source: syllabus, Held
A voluntary dismissal is final because it terminates the case, consistent with 1946 legal dictionaries and the Advisory Committee Notes to the 1946 Amendment.
Source: syllabus, Held
The Court declined to address Halliburton's jurisdictional argument about the motion to vacate, leaving it for the lower courts on remand.
Source: syllabus, Held
Justice Alito delivered the opinion for a unanimous Court.
Source: syllabus, lineup