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United States Court of Appeals for the Seventh Circuit - 143 F.3d 293
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Case Summary
In the 1998 case, Brandon v. Chicago Board of Education, the Seventh Circuit Court of Appeals ruled on whether Brandon could get relief from a judgment under Rule 60 of the Federal Rules of Civil Procedure. Brandon, a former employee of the Chicago Board of Education, sued the Board for violating his rights under the Americans with Disabilities Act. However, due to confusion with the contact information of his lawyer, all court notices were sent to the wrong lawyer. Brandon's actual lawyer did not communicate with the court or his client for over a year, and the case was dismissed for lack of progress.
When Brandon's lawyer finally found out more than a year later, he filed a motion to vacate the judgment under Rule 60(b), but made another mistake by using the wrong case number. The Court of Appeals upheld the district court's decision not to grant relief because the motion was filed too late and didn't show a good enough reason for relief. The Court also rejected Brandon's argument to apply Rule 60(b)(6) as he hadn't exhausted his remedies under Rule 60(b)(1).
This case demonstrates the importance of timeliness and diligent representation in seeking relief from judgment under Rule 60(b). It also highlights the balance between justice and fairness versus finality and efficiency in federal litigation. The case remains a relevant authority on this topic.
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The plaintiff sued the Chicago Board of Education under the Americans with Disabilities Act, but due to a clerical error, the plaintiff's attorney did not receive notice of two status hearings, leading to the case being dismissed. The plaintiff's attorney filed a Rule 60 motion to vacate the judgment, but due to another clerical error, the motion was spindled under the wrong case number. The court denied Rule 60 relief, and the appellant appealed the decision. The court clarified that relief under Rule 60(b) is mutually exclusive, and Rule 60(b)(1) is the appropriate mechanism for analyzing the request for relief. As Rule 60(b)(1) has a one-year time limit, which is jurisdictional and cannot be extended, the appellant's motion brought one year and three days after judgment was entered is not valid. Therefore, the court affirmed the district court's decision to deny relief.
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