SUPREME COURT OF THE UNITED STATES
Samuel Alito
Waetzig – Appellant
Versus
Halliburton Energy Services Inc. – Respondent
Syllabus
NOTE: Where it is feasible, a syllabus (headnote) will be released, as is
being done in connection with this case, at the time the opinion is issued.
The syllabus constitutes no part of the opinion of the Court but has been
prepared by the Reporter of Decisions for the convenience of the reader.
See United States v. Detroit Timber & Lumber Co.,
SUPREME COURT OF THE UNITED STATES
Syllabus WAETZIG v. HALLIBURTON ENERGY SERVICES, INC. CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE TENTH CIRCUIT
No. 23–971. Argued January 14, 2025—Decided February 26, 2025
Gary Waetzig filed a federal age-discrimination lawsuit against his for- mer employer Halliburton Energy Services, Inc. He later submitted his claims for arbitration, and voluntarily dismissed his federal law- suit without prejudice under Federal Rule of Civil Procedure 41(a). Af- ter losing at arbitration, he asked the District Court to reopen his dis- missed lawsuit and vacate the arbitration award, asserting Federal Rule of Civil Procedure 60(b) as the basis for reopening the suit. Fed- eral Rule of Civil Procedure 60(b) permits relief from a “final judgment, order, or proceeding.” The District Court reopened the case, finding that a voluntary dismissal without prejudice counts as a “final pro- ceeding” and that Waetzig made a mistake when he dismissed his case rather than seeking a stay. The District Court separately granted Waetzig’s motion to vacate the arbitration award. The Tenth Circuit reversed. Held: A case voluntarily dismissed without prejudice under Rule 41(a) counts as a “final proceeding” under Rule 60(b). Pp. 4–14. (a) The Court does not address Halliburton’s argument regarding jurisdiction over the motion to vacate. The question whether Rule 60(b) permits reopening a case that was voluntarily dismissed without prejudice is antecedent to jurisdictional questions about the motion to vacate. The lower courts may address those questions on remand. Pp. 4–6. (b) Text, context, and history support the conclusion that a Rule 41(a) voluntary dismissal without prejudice qualifies as a “final pro- ceeding” under Rule 60(b). Pp. 6–14. (1) A voluntary dismissal is “final” because it terminates the case. 2 WAETZIG v. HALLIBURTON ENERGY SERVICES, INC.
Syllabus
This straightforward reading aligns with legal dictionaries from 1946 (when “final” first appeared in the Rule) and is confirmed by Advisory Committee Notes to the 1946 Amendment to the Rule. The word “fi- nal” underscores that Rule 60(b) does not infringe a court’s inherent and distinct power to revise its interlocutory decrees in an ongoing case. Halliburton’s request to construe “final” consistent with jurisdic- tional statutes like 28 U. S. C. §1291, which gives the Courts of Ap- peals jurisdiction over appeals from “final decisions” of district courts, is unpersuasive. The finality concept in appellate jurisdiction serves a distinct purpose—preventing interlocutory appeals from impairing case resolution at the trial level. Finality under Rule 60(b) does not play a similar role. Unlike an appeal filed under the appellate juris- diction statute, a motion for relief under Rule 60(b) is discretionary, not a matter of statutory right. Rule 60(b) therefore does not pose the same risk to efficient case resolution before the trial courts. The Court sees no reason to import the understanding of finality that applies in the field of appellate jurisdiction to the different context of Rule 60(b). Pp. 6–9. (2) A voluntary dismissal counts as a “proceeding” under Rule 60(b). Legal dictionaries from 1938 to present suggest that the term “proceeding” encompasses all steps in an action’
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