Waetzig v. Halliburton Energy Services, Inc.

604 U.S. 305
CourtSupreme Court of the United States
DecidedFebruary 26, 2025
Docket23-971
StatusPublished

This text of 604 U.S. 305 (Waetzig v. Halliburton Energy Services, Inc.) is published on Counsel Stack Legal Research, covering Supreme Court of the United States primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Waetzig v. Halliburton Energy Services, Inc., 604 U.S. 305 (2025).

Opinion

PRELIMINARY PRINT

Volume 604 U. S. Part 1 Pages 305–320

OFFICIAL REPORTS OF

THE SUPREME COURT February 26, 2025

REBECCA A. WOMELDORF reporter of decisions

NOTICE: This preliminary print is subject to formal revision before the bound volume is published. Users are requested to notify the Reporter of Decisions, Supreme Court of the United States, Washington, D. C. 20543, pio@supremecourt.gov, of any typographical or other formal errors. OCTOBER TERM, 2024 305

Syllabus

WAETZIG v. HALLIBURTON ENERGY SERVICES, INC. certiorari to the united states court of appeals for the tenth circuit No. 23–971. Argued January 14, 2025—Decided February 26, 2025 Gary Waetzig fled a federal age-discrimination lawsuit against his former employer Halliburton Energy Services, Inc. He later submitted his claims for arbitration, and voluntarily dismissed his federal lawsuit without prejudice under Federal Rule of Civil Procedure 41(a). After losing at arbitration, he asked the District Court to reopen his dismissed lawsuit and vacate the arbitration award, asserting Federal Rule of Civil Procedure 60(b) as the basis for reopening the suit. Federal Rule of Civil Procedure 60(b) permits relief from a “fnal judgment, order, or proceeding.” The District Court reopened the case, fnding that a voluntary dismissal without prejudice counts as a “fnal proceeding” and that Waetzig made a mistake when he dismissed his case rather than seeking a stay. The District Court separately granted Waetzig's mo- tion to vacate the arbitration award. The Tenth Circuit reversed. Held: A case voluntarily dismissed without prejudice under Rule 41(a) counts as a “fnal proceeding” under Rule 60(b). Pp. 310–320. (a) The Court does not address Halliburton's argument regarding ju- risdiction over the motion to vacate. The question whether Rule 60(b) permits reopening a case that was voluntarily dismissed without preju- dice is antecedent to jurisdictional questions about the motion to vacate. The lower courts may address those questions on remand. Pp. 310–311. (b) Text, context, and history support the conclusion that a Rule 41(a) voluntary dismissal without prejudice qualifes as a “fnal proceeding” under Rule 60(b). Pp. 311–320. (1) A voluntary dismissal is “fnal” because it terminates the case. This straightforward reading aligns with legal dictionaries from 1946 (when “fnal” frst appeared in the Rule) and is confrmed by Advisory Committee Notes to the 1946 Amendment to the Rule. The word “fnal” underscores that Rule 60(b) does not infringe a court's inherent and distinct power to revise its interlocutory decrees in an ongoing case. Halliburton's request to construe “fnal” consistent with jurisdictional statutes like 28 U. S. C. § 1291, which gives the courts of appeals juris- diction over appeals from “fnal decisions” of district courts, is unpersua- 306 WAETZIG v. HALLIBURTON ENERGY SERVICES, INC.

sive. The fnality concept in appellate jurisdiction serves a distinct pur- pose—preventing interlocutory appeals from impairing case resolution at the trial level. Finality under Rule 60(b) does not play a similar role. Unlike an appeal fled under the appellate jurisdiction statute, a motion for relief under Rule 60(b) is discretionary, not a matter of statutory right. Rule 60(b) therefore does not pose the same risk to effcient case resolution before the trial courts. The Court sees no reason to import the understanding of fnality that applies in the feld of appellate juris- diction to the different context of Rule 60(b). Pp. 312–315. (2) A voluntary dismissal counts as a “proceeding” under Rule 60(b). Legal dictionaries from 1938 to present suggest that the term “proceeding” encompasses all steps in an action's progression. Other federal rules similarly treat “proceeding” as including all formal steps in an action. Halliburton and the court below assert that the term “proceeding” should be read in the context of its neighboring terms “judgment” and “order.” And because a “judgment” and “order” both involve some ju- dicial determination of rights, a “proceeding” should at least involve some judicial action or conclusive determination of rights. Although it is true that statutory terms must be read in the context of their neigh- bors, that rule cuts the other way in this case. The proposed alterna- tive reading would strip “proceeding” of independent meaning, as any judicial determination would already be an “order.” When Rule 60(b) authorizes relief from a “judgment, order, or proceeding,” the Rule speaks in an ascending order of generality. The structure of the Rule suggests that each term should be read as broader than what came be- fore. Pp. 315–318. (3) The Court's reading is buttressed by historical context, as Rule 60(b) was modeled after a California statute previously interpreted to extend to voluntary dismissals without prejudice. See Hall v. Hall, 584 U. S. 59, 72–73 (reading Rule 42(a) in light of “its statutory predeces- sor”). Pp. 318–319. 82 F. 4th 918, reversed and remanded.

Alito, J., delivered the opinion for a unanimous Court.

Vincent Levy argued the cause for petitioner. With him on the briefs were Kevin D. Benish, Jack L. Millman, Spen- cer J. Kontnik, Austin M. Cohen, and Aditi Shah. Matthew D. McGill argued the cause for respondent. With him on the brief were Jonathan C. Bond, Lochlan F. Cite as: 604 U. S. 305 (2025) 307

Opinion of the Court

Shelfer, Joshua R. Zuckerman, Patrick J. Fuster, and Heather F. Crow.* Justice Alito delivered the opinion of the Court. Federal Rule of Civil Procedure 60(b) permits a court, “[o]n motion and just terms,” to “relieve a party . . . from a fnal judgment, order, or proceeding.” The question in this case is whether Rule 60(b) permits a district court to reopen a case that was voluntarily dismissed without prejudice under Rule 41(a). We hold that such a dismissal counts as a “fnal judgment, order, or proceeding,” and thus qualifes for Rule 60(b) relief. I A This case began as an employment dispute. Petitioner Gary Waetzig is a former employee of respondent Hallibur- ton Energy Services, Inc. Following his termination, Waet- zig fled a lawsuit against Halliburton in the U. S. District Court for the District of Colorado. He alleged that he was illegally terminated on the basis of his age, in violation of the Age Discrimination in Employment Act of 1967, 81 Stat. 602, as amended, 29 U. S. C. § 621 et seq. In response, Halli- burton asserted that Waetzig was required to arbitrate his claim. Waetzig acquiesced and submitted his claims for arbitration. At that point, Waetzig could have asked the District Court to stay his federal lawsuit pending the arbitration proceed- ings. See 9 U. S. C. § 3; Smith v. Spizzirri, 601 U. S. 472, 476 (2024). Instead, he elected to dismiss the case under Federal Rule of Civil Procedure 41(a).

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