Brenda Kay Leavy v. Federal Express Corporation

Whether, in determining whether a Rule 60(b)(4) motion was filed within a “reasonable time” under Rule 60(c)(1), a court must consider the movant’s stated explanation for the timing of the motion and documented intervening efforts to obtain review.

Whether a Rule 60(b)(4) motion constitutes impermissible relitigation when the movant alleges defects in the procedures by which judgment was entered—including the failure to adjudicate an asserted federal claim and the treatment of identified record evidence and disputed material facts as though they had not been presented—rather than merely challenging the correctness of the underlying merits determination.

Whether a federal court may refuse to adjudicate a pro se plaintiff’s ADA failure-toaccommodate claim solely because the plaintiff left the corresponding box blank on a standardized complaint form, where the court itself acknowledged that the plaintiff had asserted reasonable-accommodation discrimination under the ADA.