Salazar v. District of Columbia, No. 16-7065 (D.C. Cir. 2018)Annotate this Case
While district courts generally have discretion under Federal Rule of Civil Procedure 60(b)(5) to adjust the terms of an existing consent decree in light of changed circumstances, the issuance of a new injunction must meet the strict preconditions for such exceptional relief set out in Federal Rule of Civil Procedure 65. This case stemmed from a putative class action brought by a broad group of Medicaid applicants and recipients against the District. The parties eventually reached a settlement and a consent decree was issued. Plaintiffs subsequently filed a motion for a preliminary injunction and renewals under the Affordable Care Act. About a week after briefing on the preliminary injunction concluded, plaintiffs filed a motion under Federal Rules of Civil Procedure 60(b)(5) and (b)(6) to "modify" the Consent Decree to achieve precisely the same relief as the pending motion for a preliminary injunction. The district court granted the motion to modify and denied the motion for a preliminary injunction as moot.
The DC Circuit held that the district court's order provided brand new relief based on brand new facts alleging violations of a new law without the requisite findings for an injunction, and thus it crossed the line from permissibly modifying into impermissibly enjoining. Accordingly, the court reversed the district court's judgment, vacated the new injunctive relief, and remanded for further proceedings.