STAHLMAN
v.
LANE
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Plaintiff John David Stahlman sought relief from a dismissal of his Fifth Amendment Equal Protection claim regarding prison messaging system access under Rule 60(b), arguing that the Supreme Court's overruling of the Chevron doctrine in Loper Light Enterprises v. Raimondo warranted reconsideration. The district court denied relief, holding that the original dismissal did not rely on Chevron and that intervening changes in law do not constitute extraordinary circumstances justifying Rule 60(b) relief.
Stahlman is not entitled to Rule 60(b) relief because the Court's original dismissal did not rely on the Chevron doctrine, making the Loper decision irrelevant, and because a mere intervening change in decisional law does not constitute the type of extraordinary circumstance that justifies relief under Rule 60(b).
[1] A party seeking relief from a final judgment under Federal Rule of Civil Procedure 60(b)(5) or (6) must demonstrate extraordinary circumstances.
[2] An intervening change in decisional law alone does not constitute the extraordinary circumstance required for relief under Federal Rule of Civil Procedure 60(b).
Previewing 2 of 3 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“a mere intervening change in decisional law is not the type of extraordinary circumstance that justifies relief under Rule 60(b)”
Establishes the legal standard that Stahlman's reliance on Loper's overruling of Chevron fails because changes in law alone do not warrant Rule 60(b) relief.
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Join FLexlaw to unlock all legal intelligenceStahlman filed suit in March 2023 alleging defendants violated the Fifth Amendment's Equal Protection Clause by limiting his access to a prison messag…
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Before the Court is Plaintiff John David Stahlman's Motion Requesting Relief from an Order and Additional Relief (Doc. 18). Stahlman filed this action in March 2023, alleging the defendants violated the Fifth Amendment's Equal Protection Clause by limiting his access to a prison messaging system. (Doc. 1). The Court dismissed Stahlman's complaint without prejudice for failure to state a claim and gave him leave to amend. (Doc. 15). Stahlman did not file an amended complaint, so the Court entered judgment and closed the case in July 2023. (Docs. 16 and 17).
Stahlman now seeks relief under Federal Rule of Civil Procedure 60(b)(5) and (6), which allows a court to relieve a party from a final judgment for the following reasons:
(5) the judgment has been satisfied, released or discharged; it is based on an earlier judgment that has been released or vacated; or applying it prospectively is no longer equitable; or (6) any other reason that justifies relief.
Fed. R. Civ. P. 60(b). Stahlman argues the Court's dismissal of his complaint was based on the Chevron doctrine, which the Supreme Court overruled in Loper Bright Enterprises v. Raimondo, 603 U.S. 369 (2024).
Stahlman is not entitled to Rule 60(b) relief. First, the Court did not rely on the Chevron doctrine when it dismissed Stahlman's complaint, so the Loper decision is not relevant here. Second, a mere intervening change in decisional law is not the type of extraordinary circumstance that justifies relief under Rule 60(b). See Arthur v. Thomas, 739 F. 3d 611, 632 (11th Cir. 2014); see also Mock v. Bell Helicopter Textron, Inc., 373 F. App'x 989, 991-92 (11th Cir. 2010).
Accordingly, Plaintiff John David Stahlman's Motion Requesting Relief from an Order and Additional Relief (Doc. 18) is denied.
DONE and ORDERED in Fort Myers, Florida on June 4, 2025.
Sheri Polster Rappell
SHERI POLSTER CHAPPELL
UNITED STATES DISTRICT JUDGE
SA: FTMP-1 Copies: All Parties of Record
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Loper Bright Enters. v. Raimondo, 603 U.S. 369 (U.S. 2024)
- Arthur v. Thomas, 739 F.3d 611 (11th Cir. 2014)