Waetzig v. Halliburton Energy Services, Inc. (Arbitration / Civil Procedure)

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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.