Reopening judgments for court mistakes
Kemp v. United States
In brief
A judge's legal error can qualify as a "mistake" under Rule 60(b)(1), but a request for relief must be filed within one year.
- Where it stands
- Decided
Decided 8-1 · June 13, 2022 · Opinion by Justice Thomas
- What it’s about
- This case was about whether a federal court can reopen a final judgment under Rule 60(b)(1) when the district judge made a legal error.
- Who it affects
- People seeking to reopen a federal judgment because a judge made a legal error may use Rule 60(b)(1). For example, a federal litigant must file that kind of request within one year.
Summary: written with AI from the case record.
What it's about
The Supreme Court held that the rule’s reference to a "mistake" does include a judge’s error of law, although Kemp’s request was still too late under the rule’s one-year deadline.
The case clarifies when a federal court may revisit a final judgment under Rule 60(b)(1).
Question presented
Whether Rule 60(b)(1) authorizes relief based on a district court ’ s error of law.
What the Court decided
Holding
The term “mistake” in Rule 60(b)(1) includes a judge’s errors of law. Because Kemp’s motion alleged such a legal error, it was cognizable under Rule 60(b)(1) and untimely under Rule 60(c)’s 1-year limitations period. 573, affirmed.
- Result
- Affirmed
The vote
What's next
The Supreme Court has finished this docket action. Kemp could not obtain relief under Rule 60(b)(1) because his request was filed too late.
Documents
Docket activity
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AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
AI analysis generated: Decision Record
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AI analysis generated: Case Briefing
Case data updated: status, opinion_date
Opinion added: opinion
Brief added: Petition
Brief added: Questions Presented
More questions
- What did the Supreme Court rule in Kemp v. United States?
- The Court said Rule 60(b)(1) covers a district judge's legal error. Kemp still lost because his request came after one year.
- Who is affected by the Kemp decision?
- Federal litigants seeking to reopen a final judgment based on a judge's legal error are affected. They must make that request within one year.
- What happens next in Kemp v. United States?
- The Supreme Court's action is complete. Kemp's request to reopen the judgment remains untimely under the one-year deadline.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.