Bruzzese v. Bondi

CourtCourt of Appeals for the Second Circuit
DecidedMarch 10, 2026
Docket25-146
StatusUnpublished

This text of Bruzzese v. Bondi (Bruzzese v. Bondi) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bruzzese v. Bondi, (2d Cir. 2026).

Opinion

25-146 Bruzzese v. Bondi

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

SUMMARY ORDER

RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL.

At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 10th day of March, two thousand twenty-six.

PRESENT: REENA RAGGI, ALISON J. NATHAN, Circuit Judges. JESSE M. FURMAN, District Judge. * _____________________________________

Adam Bruzzese,

Plaintiff-Appellant,

v. 25-146

* Judge Jesse M. Furman, of the United States District Court for the Southern District of New York, sitting by designation. Pamela Bondi, United States Attorney General,

Defendant-Appellee. _____________________________________

FOR PLAINTIFF-APPELLANT: ADAM BRUZZESE, pro se, Farmingdale, NY.

FOR DEFENDANT-APPELLEE: VARUNI NELSON, David A. Cooper, Assistant United States Attorneys, for Joseph Nocella, Jr., United States Attorney for the Eastern District of New York, Brooklyn, NY.

Appeal from a judgment of the United States District Court for the Eastern

District of New York (Donnelly, J.).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED,

ADJUDGED, AND DECREED that the November 20, 2024 judgment of the

district court is AFFIRMED.

Adam Bruzzese, pro se, appeals from the district court’s order denying his

motion for relief pursuant to Federal Rule of Civil Procedure 60. In 2013, Bruzzese

sued the Attorney General, claiming that his reassignment from a law enforcement

2 position within the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) to

a non-law enforcement position within the agency violated the Rehabilitation Act

of 1973, 29 U.S.C. § 791 et seq. In 2016, the district court granted the defendant’s

motion for summary judgment because Bruzzese had failed to show that he was a

covered “individual with a disability” under the statute or “otherwise qualified”

for his original position, id. § 794(a), and even if he had, Bruzzese’s supervisor had

established legitimate, non-pretextual reasons for reassigning him, see Bruzzese v.

Lynch, 191 F. Supp. 3d 237 (E.D.N.Y. 2016). This Court affirmed. See Bruzzese v.

Sessions, 725 F. App’x 68 (2d Cir. 2018).

Nearly eight years after the district court’s 2016 judgment, Bruzzese moved

for relief from that judgment pursuant to Federal Rules of Civil Procedure 60(b)(6),

(d)(1), and (d)(3). This marks Bruzzese’s third attempt to attain post-judgment

relief from the 2016 order. 1 He claims in the instant motion that ATF in 2023

referred an unnamed law enforcement agent, “GS1,” to a psychological fitness

evaluation, but that GS1—unlike Bruzzese—was returned to his previous law

1 See Bruzzese v. Garland, No. 13-cv-5733, 2021 WL 1964547 (E.D.N.Y. May 17, 2021), aff’d, No. 21-1448, 2022 WL 1669191 (2d Cir. May 26, 2022); Bruzzese v. Dettelbach, No. 22-cv- 7948, 2023 WL 7448757 (E.D.N.Y. Feb. 15, 2023), aff’d, No. 23-239, 2023 WL 7391658 (2d Cir. Nov. 8, 2023).

3 enforcement position after the evaluation, demonstrating that the agency’s

reassignment of Bruzzese was pretextual and violated due process. Appellant’s

Br. at 9–10.

The district court denied Bruzzese’s motion. First, it concluded that

Bruzzese could not use Rule 60(b)(6) to repeat arguments that had been raised and

rejected in prior proceedings. See Bruzzese v. Garland, No. 13-cv-5733, 2024 WL

5347130, at *4 (E.D.N.Y. Nov. 20, 2024). Second, it dismissed his Rules 60(d)(1) and

(d)(3) arguments because Bruzzese failed to allege sufficient facts to meet the more

stringent standards applicable to those Rules. See id. at *4–5. We agree. We

assume the parties’ familiarity with the underlying facts and proceedings, to

which we refer only as necessary to explain our decision to affirm.

“We review the district court’s Rule 60 decision for abuse of discretion.”

United Airlines, Inc. v. Brien, 588 F.3d 158, 175 (2d Cir. 2009); see also Marco Destin,

Inc. v. Levy, 111 F.4th 214, 219 (2d Cir. 2024) (“[W]e review the grant or dismissal

of an independent action for fraud on the court under Rule 60(d)(3) for abuse of

discretion.”). 2

2 The only exception to this general rule is the district court’s decision on a Rule 60(b)(4) motion for relief from a void judgment, which we review de novo. See Cent. Vermont Pub.

4 Rule 60(b)(6) may be successfully invoked only when the plaintiff

demonstrates “extraordinary circumstances” justifying relief. Mandala v. NTT

Data, Inc., 88 F.4th 353, 361 (2d Cir. 2023) (internal quotations omitted). Rules

60(d)(1) and (d)(3), for their parts, provide that a court may “entertain an

independent action to relieve a party from a judgment,” Fed. R. Civ. P. 60(d)(1), or

“set aside a judgment for fraud on the court,” Fed. R. Civ. P. 60(d)(3), but both

come with demanding requirements for the movant. An “independent action”

under Rule 60(d)(1) is “available only to prevent a grave miscarriage of justice.”

United States v. Beggerly, 524 U.S. 38, 47 (1998). And “fraud on the court” under

Rule 60(d)(3) requires a showing that “the defendant interfered with the judicial

system’s ability to adjudicate impartially and that the acts of the defendant [were]

of such a nature as to have prevented the plaintiff from fully and fairly presenting

a case or defense.” Mazzei v. The Money Store, 62 F.4th 88, 93–94 (2d Cir. 2023).

Construing Bruzzese’s pro se motion and brief to raise the strongest

arguments they suggest, see McLeod v. Jewish Guild for the Blind, 864 F.3d 154, 156

Serv. Corp. v. Herbert, 341 F.3d 186, 189 (2d Cir. 2003). Although Bruzzese claims that de novo review applies here, he does not cite Rule 60(b)(4) as grounds for relief in his brief, nor did he cite that Rule in his motion before the district court.

5 (2d Cir. 2017), we conclude that the district court did not abuse its discretion by

denying Bruzzese’s Rule 60 motion.

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Related

United Airlines, Inc. v. Brien
588 F.3d 158 (Second Circuit, 2009)
United States v. Beggerly
524 U.S. 38 (Supreme Court, 1998)
Competex, S.A. (In Liquidation) v. Ronald Labow
783 F.2d 333 (Second Circuit, 1986)
McLeod v. the Jewish Guild for the Blind
864 F.3d 154 (Second Circuit, 2017)
Bruzzese v. Lynch
191 F. Supp. 3d 237 (E.D. New York, 2016)
Mazzei v. the Money Store
62 F.4th 88 (Second Circuit, 2023)
Mandala v. NTT Data, Inc.
88 F.4th 353 (Second Circuit, 2023)
Marco Destin, Inc. v. Levy
111 F.4th 214 (Second Circuit, 2024)

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