Giles v. St Luke's Northland-Smithville, No. 17-2856 (8th Cir. 2018)
Annotate this CaseThe Eighth Circuit affirmed the district court's grant of summary judgment for Saint Luke's in an employment discrimination action. The court held that the district court did not abuse its discretion in denying defendant's motion to reconsider under Federal Rule of Civil Procedure 60(b)(1). The court explained that, although defendant's delay was brief, Saint Luke's made no claim of prejudice and defendant did not act in bad faith, such factors did not outweigh defendant's carelessness or mistake in construing the rules and the absence of any apparent meritorious defense. Furthermore, there were no exceptional circumstances in this case that warranted relief under Rule 60(b)(6).
Court Description: Per Curiam - Before Wollman, Kelly and Erickson, Circuit Judges] Civil case - Employment discrimination. The district court denied plaintiff's untimely motion for additional time to respond to defendant's summary judgment motion and granted defendant summary judgment; the court treated plaintiff's motion for reconsideration as a Rule 60(b)(1) motion and did not abuse its discretion by denying the motion; while the delay was relatively brief, defendant made no claim of prejudice and the plaintiff did not act in bad faith, these factors did not outweigh plaintiff's carelessness or mistakes in construing the rules and the absence of any meritorious defense; the case did not present the kind of exceptional circumstances warranting relief under Rule 60(b)(6).
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