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No. 23-971October Term 2024Decided Feb 26, 2025

Docket 23-971October Term 2024 (2024–2025)

Gary Waetzig, Petitioner v. Halliburton Energy Services, Inc.

The Supreme Court ruled unanimously that a plaintiff who voluntarily dismisses their lawsuit without prejudice under Federal Rule of Civil Procedure 41(a) can later ask a court to reopen the case under Rule 60(b).

Case status

Current stage
Decided
Latest event
Decision released Feb 26, 2025
Case Accepted
Arguments HeardJan 14, 2025
Decision ReleasedFeb 26, 2025
What it's about

The Supreme Court ruled unanimously that a plaintiff who voluntarily dismisses their lawsuit without prejudice under Federal Rule of Civil Procedure 41(a) can later ask a court to reopen the case under Rule 60(b). The Court determined that such a dismissal qualifies as a "final proceeding," allowing district courts to correct mistakes or provide relief even after a case has been voluntarily withdrawn.

Question presented

Is a voluntary dismissal without prejudice under Federal Rule of Civil Procedure 41 a “final judgment, order, or proceeding” under Federal Rule 60(b)?

Case path

United States Court of Appeals for the Tenth Circuit / Decision released Feb 26, 2025

Area

Decided Supreme Court case