Hobbs v. Willis

CourtDistrict Court, E.D. Wisconsin
DecidedAugust 19, 2022
Docket2:22-cv-00467
StatusUnknown

This text of Hobbs v. Willis (Hobbs v. Willis) is published on Counsel Stack Legal Research, covering District Court, E.D. Wisconsin primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hobbs v. Willis, (E.D. Wis. 2022).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN

LAWRENCE HOUSTON HOBBS,

Plaintiff, Case No. 22-cv-467-pp v.

NICHOLAS WILLIS, ALEJANDRO PADILLA, TIM ZARZECKI, CHRISTOPHER SMITH, BRIAN SMITH, JOHN/DOE, and MOUNT PLEASANT POLICE DEPARTMENT,

Defendants.

ORDER DENYING PLAINTIFF’S MOTION TO ALTER OR AMEND ORDER (DKT. NO. 5)

On May 26, 2022, the court denied the plaintiff’s motion to file electronically and to use certain electronic devices in the courtroom. Dkt. No. 4. The court found that the plaintiff had not presented extraordinary circumstances requiring permission to e-file and that this district has no rule permitting the use of unofficial recording devices because it uses court reporters and electronic recording (with audio recordings of hearings made available to the public on the docket). Id. at 2-4. The plaintiff has filed a motion to amend or correct the court’s order under Fed. R. Civ. P. 59(e) or 60(b). Dkt. No. 5. In the alternative, he asks the court to treat his motion as a Rule 5 request for permission to appeal. Id. at 4. As the court explained in its May 26, 2022 order, the court presides over many cases filed by self-represented plaintiffs who do not encounter mail- related filing delays. Dkt. No. 4 at 3. Even if a self-represented plaintiff runs into a problem caused by a mail delay, the court has the discretion to extend deadlines to accommodate that plaintiff—it would not be the plaintiff’s fault if the U.S. mail caused the delay. The court has no reason to modify its order and

the rules the plaintiff cited do not support his arguments. I. Motion to Alter or Amend Judgment Under Rule 59(e) Rule 59(e) states that a motion to alter or amend a judgment must be filed no later than twenty-eight days after the entry of the judgment. The order the court issued on May 26, 2022 was not a judgment. Technically, then, Rule 59(e) does not apply. Even if it did, the plaintiff has not stated a basis for the court to alter or amend the order under the Rule 59(e) standard. “Altering or amending a

judgment under Rule 59(e) is permissible when there is newly discovered evidence or there has been a manifest error of law or of fact.” Harrington v. City of Chi., 433 F.3d 542, 546 (7th Cir. 2006) (citing Bordelon v. Chi. Sch. Reform Bd. of Trs., 233 F.3d 524, 529 (7th Cir. 2000)). A manifest error is not demonstrated by the disappointment of the losing party, but rather is the “wholesale disregard, misapplication, or failure to recognize controlling precedent.” Oto v. Metro. Life Ins. Co., 224 F.3d 601, 606 (7th Cir.

2000) (quoting Sedrak v. Callahan, 987 F. Supp. 1063, 1069 (N.D. Ill. 1997)). “Reconsideration is not an appropriate forum for rehashing previously rejected arguments or arguing matters that could have been heard during the pendency of the previous motion.” Ahmed v. Ashcroft, 388 F.3d 247, 249 (7th Cir. 2004) (quoting Caisse Nationale de Credit Agricole v. CBI Indus., Inc., 90 F.3d 1264, 1270 (7th Cir. 1986)). Rule (59)(e) allows a court to alter or amend a judgment if the party files the motion “no later than 28 days after the entry of the judgment.”

The court received the plaintiff’s motion within twenty-eight days of its order, so if Rule 59(e) did apply, the motion would be timely filed. In the motion, the plaintiff asserts that other federal courts—particularly the Western District of Texas—have granted his requests to e-file and to use his own electronic devices in the courtroom. Dkt. No. 5 at 3, 8. He repeats his argument that untimely mail deliver would unfairly prejudice his case; he says such prejudice already has occurred, arguing that “[s]aid concern was immediately manifested pursuant to the Courts mailing of its Orders, on or about May 26th,

2022, as the causal effect that, any order made by this Court can expire pursuant to its own terms, before legal notice is fully executed.” Id. at 5. The plaintiff says that he could not research, prepare and present a reply pleading within three days, “as the majority of time to respond, pursuant to the legal authority cited herein, had elapsed.” Id. The plaintiff has not identified any newly discovered evidence or manifest error of law or fact. The plaintiff alleges that he already has been prejudiced by

having to file by mail, because he was denied the ability to file a reply pleading in three days. He does not explain what rule would have required him to file a reply pleading in three days, or what he would have been replying to. No reply pleading was required because, at the time the court issued its order, the defendants had not yet answered or otherwise responded to the complaint. The court received the plaintiff’s motion to reconsider in a timely fashion. The plaintiff states that the court should amend its order because of “mistake, inadvertence, surprise, or excusable neglect” or “newly discovered

evidence which by due diligence could not have been discovered in time or move for a new trial under Rule 59(b).” Id. at 9. The “mistake, inadvertence, surprise, or excusable neglect” standard is not the Rule 59(e) standard; it is Rule 60(b) that allows a court to change or correct an order based on mistake, inadvertence, surprise, or excusable neglect. And the “mistake, inadvertence, surprise, or excusable neglect” the plaintiff mentions is his assumption that the court was unaware that the Western District of Texas had granted a similar motion, and his argument that the doctrine of stare decisis requires this court

to follow the Texas court’s rulings. Id. The plaintiff misapprehends the stare decisis doctrine. It is true that stare decisis requires a court to decide a case “in accordance with what has been decided previously in other, similar cases (similar in the sense of not being legally distinguishable) . . . .” Colby v. J.C. Penney Co., Inc., 811 F.2d 1119, 1122-23 (7th Cir. 1987). But there is more to it than that. “The distinction essential to understanding the doctrine is between

the persuasiveness and the authority of a previous decision.” Id. at 1123. “Any decision may have persuasive force . . . .” Id. But that decision also must be “authoritative” for stare decisis to require that another court follow it. Whether a decision is authoritative depends on a variety of factors, of which the most important is the relationship between the court that decided it and the court to which it is cited later as precedent. The simplest relationship is hierarchical: the decisions of a superior court in a unitary system bind the inferior courts.

Id. While this court respects its sister court in the Western District of Texas and while its reasoning likely is persuasive, that court’s decisions are not “authoritative” as to this court. The federal court system is a unitary, hierarchical system: district courts (trial courts) at the lowest tier of the hierarchy, circuit courts (like the Seventh Circuit Court of Appeals) on the middle tier and the United States Supreme Court at the top.

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