In Waetzig v. Halliburton Energy Services, Inc. (S.Ct. No. 23-971, 2/26/25), the U.S. Supreme Court unanimously held that voluntary dismissals under F.R.C.P. Rule 41(a) may constitute final orders under Rule 60(b), thus paving the way for previously dismissed claims to be reopened. Here, Waetzig filed suit for age discrimination, but after notice of an arbitration agreement, voluntarily dismissed the suit under Rule 41(a), which operated as without prejudice. After losing on summary judgment in arbitration – instead of filing a new action attacking the arbitration award – Waetzig filed a motion under the prior docket seeking to reopen the case under Rule 60(b) based on “mistake, inadvertence, surprise or excusable neglect.” In reversing the Seventh Circuit, and without expressing an opinion on the merits of the plaintiff’s motion, the Court held that when the requirements of Rule 60(b) are satisfied, a district court “may” relieve a party from such a dismissal and reopen the case.
SCOTUS: It’s Not Over Until It’s Over
