韦茨格诉哈里伯顿能源服务公司案

Gary Waetzig filed an age-discrimination lawsuit against his former employer, Halliburton Energy Services, Inc., under the Age Discrimination in Employment Act.Halliburton moved to enforce an arbitration clause, and Waetzig voluntarily dismissed his federal lawsuit without prejudice under Federal Rule of Civil Procedure 41(a).After losing in arbitration, Waetzig moved to reopen his dismissed case under Rule 60(b), which permits relief from a "final judgment, order, or proceeding."The District Court reopened the case, but the Tenth Circuit reversed, holding that a voluntary dismissal without prejudice is not a "final proceeding."The Supreme Court granted certiorari to resolve the circuit split.

On February 26, 2025, the U.S. Supreme Court ruled unanimously in favor of Waetzig, holding that a case voluntarily dismissed without prejudice under Rule 41(a) counts as a "final proceeding" under Rule 60(b).Justice Samuel A. Alito Jr. delivered the opinion.The Tenth Circuit's decision was reversed and the case remanded for further proceedings.

Whether a voluntary dismissal without prejudice under Federal Rule of Civil Procedure 41(a) constitutes a "final judgment, order, or proceeding" under Rule 60(b), thereby permitting a district court to reopen the case.

The unanimous decision resolved a circuit split, providing clarity that plaintiffs who voluntarily dismiss cases without prejudice may seek to reopen them under Rule 60(b).The ruling affirmed that "proceeding" under Rule 60(b) encompasses all steps in an action's progression, including voluntary dismissals that terminate the case.This decision affects federal courts' ability to grant relief to parties who dismissed cases due to mistake, fraud, or other grounds under Rule 60(b).