Independent actions must, if Fed. R. Civ. P. 60(b) is to be interpreted as a coherent whole, be reserved for those cases of injustices which, in certain instances, are deemed sufficiently gross to demand a departure from rigid adherence to the doctrine of res judicata. Under the rule, an independent action should be available only to prevent a grave miscarriage of justice.
Petitioner United States brought an action under the QTA to settle a dispute with respondent claimants over the ownership of certain land on an island off the coast of Mississippi. After a discovery period, a settlement was reached and judgment entered thereon. Respondents later discovered evidence that the disputed land had been conveyed to a private party prior to the Louisiana Purchase and, therefore, title could not have passed to the United States. Respondents brought an independent action under Rule 60(b) to reopen the prior judgment, claiming that the information should have been provided in discovery in that action, but the district court dismissed. The appellate court reversed the district court’s dismissal and quieted title to the land in favor of respondents. Petitioner was granted a writ of certiorari to review the judgment of the appellate court. The Supreme Court of the United States reversed the appellate court’s judgment.
Did the appellate court err in concluding that there was a sufficient basis to justify the reopening of the settlement judgment and in deciding that equitable tolling was available in a QTA suit?
Independent actions under Rule 60(b) were limited to cases of grave miscarriage of justice, and no such gross injustice was shown to justify reopening the settlement judgment. Moreover, the action was not brought within 12 years after respondent claimants learned of the petitioner United States' claim in the land, as required by § 2409(g), the limitation provision of the QTA.