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In Waetzig v. Halliburton Energy Services, Inc., the Supreme Court held that a case voluntarily dismissed without prejudice under Federal Rule of Civil Procedure 41(a) qualifies as a "final proceeding" under Rule 60(b), allowing a district court to reopen the case. Gary Waetzig sued Halliburton for age discrimination but later dismissed his case without prejudice and pursued arbitration. After losing in arbitration, he sought to reopen his federal case and vacate the arbitration award under Rule 60(b). The district court granted his motion, but the Tenth Circuit reversed. Writing for a unanimous Court, Justice Alito explained that the text, context, and history of Rule 60(b) support treating a voluntary dismissal as final for purposes of post-judgment relief. The ruling clarifies that Rule 60(b) relief is discretionary and distinct from appellate finality, ensuring courts retain flexibility to revisit cases when necessary. The Court reverses and remands for further proceedings.

Justice Alito delivered the opinion for a unanimous Court.

Read by RJ Dieken.

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In Glossip v. Oklahoma, the Supreme Court held that a criminal defendant is entitled to a new trial when the prosecution knowingly fails to correct false testimony and that error could have contributed to the verdict. Richard Glossip was convicted and sentenced to death based primarily on the testimony of Justin Sneed, who claimed Glossip orchestrated the 1997 murder of Barry Van Treese. Years later, newly discovered evidence revealed that the prosecution withheld key documents, allowed Sneed to give false testimony about his mental health history, and engaged in other misconduct. Oklahoma’s attorney general ultimately conceded that Glossip’s conviction was tainted and supported granting him a new trial, but the Oklahoma Court of Criminal Appeals rejected the argument and upheld the conviction. The Supreme Court ruled that the prosecution’s failure to correct Sneed’s false testimony violated Napue v. Illinois, which prohibits the government from allowing false evidence to go unchallenged. Given that Sneed’s credibility was central to Glossip’s conviction, the Court found a reasonable likelihood that the error influenced the jury and reversed the lower court’s decision, granting Glossip a new trial.

Justice Sotomayor delivered the opinion of the Court, joined by Chief Justice Roberts and Justices Kagan, Kavanaugh, and Jackson, with Justice Barrett joining in part. Justice Barrett also filed a separate opinion concurring in part and dissenting in part. Justice Thomas filed a dissenting opinion, joined by Justice Alito, with Justice Barrett joining certain sections. Justice Gorsuch took no part in the decision.

Read by Jeff Barnum.

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In Lackey v. Stinnie, the Supreme Court held that plaintiffs who secure only preliminary injunctive relief before their case becomes moot do not qualify as "prevailing parties" entitled to attorney’s fees under 42 U.S.C. §1988(b). Virginia drivers challenged the constitutionality of a law suspending licenses for unpaid court fines. After a district court granted a preliminary injunction, the Virginia General Assembly repealed the law, and restored licenses -- making the case moot. Writing for the Court, Chief Justice Roberts explains that preliminary injunctions do not constitute enduring, merits-based relief because they are temporary and do not resolve the case. The ruling reinforces prior precedents, including Buckhannon Board & Care Home v. West Virginia DHHR and Sole v. Wyner, requiring a judicially sanctioned, enduring change in the legal relationship between parties to qualify for attorney’s fees. The Court also notes that this decision does not apply to consent decrees, since that does provide lasting relief that's sanctioned by a court. The Court reverses the Fourth Circuit's en banc decision, emphasizing a bright-line rule to ensure clarity in fee disputes.

Chief Justice Roberts writing for the majority, joined by Justices Thomas, Alito, Kagan, Gorsuch, Kavanaugh, and Barrett. Justice Jackson filed a dissenting opinion, which was joined by Justice Sotomayor.