Case Explained: Devin Thibodeaux; Herby Angelle Plaintiffs— v. Adam Bernhard

Court: United States Court of Appeals for the Fifth Circuit Filed: 2026-06-22 The Fifth Circuit affirmed the district court’s denial of a Federal Rule of Civil Procedure 60(b)(1) motion filed by defendants seeking to overturn a summary judgment dismissal with prejudice. The court applied an abuse of discretion standard, evaluating the motion against the eight factors established in *Seven Elves, Inc. v. Eskenazi* to balance the finality of judgments against the demands of justice. The court held that the district court did not abuse its discretion because the defendants’ motion effectively served as a substitute for an appeal and sought to relitigate arguments previously rejected on the merits regarding admiralty jurisdiction. The opinion emphasized that Rule 60(b)(1) cannot be used to extend the time for filing an appeal, noting the motion was filed after the appeal window had closed. Furthermore, because the underlying dismissal was a summary judgment on the merits rather than a default or procedural dismissal, the defendants had ample opportunity to present their jurisdictional arguments earlier. The court also found that the defendants’ desire to avoid future federal litigation did not constitute sufficient prejudice to warrant disturbing the final judgment in their favor. As a result of this affirmation, the district court’s summary judgment dismissing the plaintiffs’ claims with prejudice remains in effect, and the defendants’ attempt to reopen the case based on newly proffered evidence or alleged legal error is foreclosed. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.