Supreme Court Weighs Procedural Limits on Reopening Voluntarily Dismissed Cases Under Rule 60(b)

According to a Westlaw Today article by attorney Amy Grossberg, the US Supreme Court heard oral arguments in January 2025 in Waetzig v. Halliburton Energy Services Inc., a case addressing the procedural limits on whether a federal district court can reopen a case under Federal Rule of Civil Procedure 60(b) after the plaintiff voluntarily dismissed it without prejudice under Rule 41(a)(1)(A)(i). 

The case challenges the 10th Circuit’s ruling that such dismissals strip district courts of jurisdiction to consider motions to reopen, creating a circuit split on the issue.

Case Background

Gary Waetzig, a former account leader at Halliburton, sued the company in February 2020 for alleged age discrimination under the Age Discrimination in Employment Act (ADEA) after being terminated at age 66. Waetzig voluntarily dismissed his suit two months later under Rule 41(a)(1)(A)(i), citing an agreement to arbitrate. 

The arbitrator later granted Halliburton summary judgment. Seeking relief from the arbitration outcome, Waetzig filed a motion to reopen his case under Rule 60(b) in district court instead of initiating a new action to vacate the arbitration award under the Federal Arbitration Act. The district court granted his motion, reopened the case, and vacated the arbitration award. Halliburton appealed.

Court’s Ruling

The 10th Circuit reversed, holding that a Rule 41(a)(1)(A)(i) voluntary dismissal is not a “final judgment, order, or proceeding” under Rule 60(b), thus divesting the district court of jurisdiction. The majority labeled the interaction between the rules as a “procedural puzzle,” while the dissent argued that such dismissals could qualify as proceedings for Rule 60(b) purposes.

Takeaways

In-house counsel should monitor the Supreme Court’s ruling, as it could impact strategies for resolving disputes through arbitration and procedural decisions around dismissals. Additionally, the case highlights the importance of understanding how procedural rules may affect jurisdiction and post-dismissal relief options.