Snell v. Gustafson

CourtDistrict Court, W.D. Virginia
DecidedMay 19, 2025
Docket3:21-cv-00024
StatusUnknown

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

Bluebook
Snell v. Gustafson, (W.D. Va. 2025).

Opinion

CLERKS OFFICE U.S. DIST. CC AT LYNCHBURG, VA FILED UNITED STATES DISTRICT COURT 5/19/2095 WESTERN DISTRICT OF VIRGINIA LAURA A. AUSTIN, CLERK CHARLOTTESVILLE DIVISION BY: s/CARMEN AMOS DEPUTY CLERK MARCIA M. SNELL , CASE NO. 3:21-cv-00024 Plaintiff, “v

v. MEMORANDUM OPINION BUFFY JO GUSTAFSON, et al., JUDGE NORMAN K. Moon Defendants.

Plaintiff Marcia Snell moves for relief from judgment under Federal Rule of Civil Procedure 60(b)(1). See Dkt. 495 (amended motion); Dkt. 496 (mem. in support). As explained below, Plaintiff's motion is GRANTED in part and DENIED in part, on the basis that the Court considered inadmissible evidence in ruling on the motion for summary judgment. A separate order will issue.

1. Procedural History At the outset of this case, Plaintiff Marcia Snell raised five causes of action against Defendants Rebecca A. Reid, Buffo Jo Gustafson, Hasbrouck Real Estate Corporation (“Hasbrouck” or “HBREC”), alleging that, inter alia, the defendants were liable for constructive fraud when they misrepresented the state of a hand railing that later injured Plaintiff. This Court granted summary judgment in favor of Defendants Gustafson and HBREC on the constructive fraud claim and dismissed them from the case. Dkt. 250. Meanwhile, Plaintiff's case against Reid proceeded to a jury trial. After the jury found that Reid was not liable for constructive fraud, Dkt.

296, Plaintiff appealed the jury verdict and the Court’s grant of summary judgment as to Defendants Gustafson and HBREC. Dkt. 310. The Fourth Circuit affirmed in part and reversed in part. Snell v. Reid, No. 22-1869, 2024 WL 2815061 (4th Cir. June 3, 2024). Pertinent here, the Fourth Circuit vacated the Court’s grant of summary judgment to Gustafson and HBREC on Plaintiff’s constructive fraud claim. Snell, 2024 WL 2815061, at *2. The Fourth Circuit held that this Court erred when it “rejected Snell’s constructive fraud claim against the management defendants due to those defendants’ lack of

involvement in or knowledge of the painting or repair of the subject stairs.” Id. The Fourth Circuit explained that “Snell’s constructive fraud claim against the management defendants centered around Gustafson’s alleged statements during a pre-rental walkthrough,” and that, for purposes of constructive fraud, “it is irrelevant whether Gustafson knew those statements were false at the time she allegedly made them.” Id. Accordingly, the case was remanded for further proceedings consistent with the Fourth Circuit opinion, and this Court entered a scheduling order to docket Plaintiff’s constructive fraud claim against Defendants Gustafson and HBREC as the sole remaining cause of action in the case. Dkt. 413. Substantial pre-trial motions practice ensued. Plaintiff and Defendants moved for summary judgment, and Plaintiff filed various motions in limine to admit and exclude evidence. Relevant

here, Defendants moved for leave to amend their answer to add the affirmative defense of res judicata. Dkt. 434. Defendants then moved for summary judgment based on res judicata. Dkt. 438. The Court granted Defendants’ motion to amend their answer to plead res judicata, and likewise granted Defendants’ motion for summary judgment, finding that the elements of claim preclusion and issue preclusion were met and that no dispute of material fact existed to contradict this conclusion. See Dkt. 487 (memorandum opinion); Dkt. 488 (order). Plaintiff now moves for relief from that judgment under Federal Rule of Civil Procedure 60(b)(1). See Dkt. 495 (amended motion); Dkt. 496 (mem. in support). II. Legal Standard

Federal Rule of Civil Procedure 60(b) allows a court to “relieve a party . . . from a final judgment, order or proceeding” on a limited number of grounds. Fed. R. Civ. P. 60(b). “To prevail, a party must demonstrate (1) timeliness, (2) a meritorious defense, (3) a lack of unfair prejudice to the opposing party, and (4) exceptional circumstances.” Wells Fargo Bank, N.A. v. AMH Roman Two NC, LLC, 859 F.3d 295, 299 (4th Cir. 2017) (citing Dowell v. State Farm Fire & Cas. Auto. Ins. Co., 993 F.2d 46, 48 (4th Cir. 1993)). “Once a party has met this threshold, he must then show that he qualifies for relief under one of the six specific categories listed in Rule 60(b).” Justus v. Clarke, 78 F.4th 97, 105–06 (4th Cir. 2023). Of the six categories, subsection (b)(1) permits a court to relieve a party from a final

judgment when the judgment is compromised by “mistake, inadvertence, surprise, or excusable neglect.” Fed. R. Civ. P. 60(b)(1). The term “mistake” encompasses a judge’s error of law, both obvious and non-obvious. See Kemp v. U.S., 596 U.S. 528, 533-34 (2022) (“Rule 60(b)(1) covers all mistakes of law made by a judge.”). Any Rule 60(b) motion must be made within a “reasonable time,” and, for subsections (1) through (3), a reasonable time means “no more than a year after the entry of the judgment or order or the date of the proceeding.” Fed. R. Civ. P. 60(c).

III. Discussion As a preliminary matter, Plaintiff has met the threshold showing for a Rule 60(b) motion because (i) her motion was timely filed (only weeks after the Court issued judgment), (ii) she presents exceptional circumstances and a meritorious defense by pointing to legal error that undermines the Court’s judgment and potentially refutes summary dismissal, and (iii) Defendants are not prejudiced by relief from the judgment, since they had due notice of the motion for relief and will be granted leave to file a renewed motion for summary judgment. As a substantive matter, Plaintiff argues that she is entitled to relief from the Court’s judgment on four grounds of legal “mistake.” See Fed. R. Civ. P. 60(b)(1). First, she argues that the Court erred in applying Virginia law, as opposed to federal law, when determining the date on which the Reid judgment became final for claim preclusion purposes. Second, she argues that,

but for the Court’s purported choice of law error, the Court would not have granted Defendants’ leave to belatedly plead their res judicata defenses, such that their belated defenses should now be stricken. Third, she argues that even if leave to amend was proper, Defendants are judicially estopped from asserting res judicata since they previously argued that it did not apply in this case. Finally, she argues that the Court erred in granting summary judgment when it relied on inadmissible evidence or otherwise incorrectly granted summary judgment when disputes of material fact remained. The Court rejects all of Plaintiff’s arguments save her last. We nonetheless address each argument fully in order to streamline future litigation in this case.

A.

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Snell v. Gustafson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/snell-v-gustafson-vawd-2025.