Kemp v. United States
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Kemp v. United States and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Kemp v. United States.
In Kemp v. United States, the Supreme Court addressed whether a judge's legal errors fall under the term 'mistake' in Rule 60(b)(1) of the Federal Rules of Civil Procedure. The Court concluded that such errors are included, making Kemp's motion untimely under Rule 60(c)'s one-year limitations period. The decision clarifies the scope of 'mistake' in procedural rules, impacting the timeliness of motions seeking relief from judgments.
Holding
The single most important “bottom line” of what the Court decided in Kemp v. United States.
The Court held that the term 'mistake' in Rule 60(b)(1) includes a judge's errors of law, making Kemp's motion untimely.
Constitutional Concepts
These are the Constitution-related themes that appear in Kemp v. United States. Click a concept to see other cases that involve the same idea.
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Why Procedural Due Process is relevant to Kemp v. United States
The case involves the application of procedural rules regarding the timeliness of motions and the interpretation of 'mistake' under Rule 60(b)(1), which relates to fair procedures in judicial processes.
Syllabus excerpt (verbatim)Kemp's motion to reopen his § 2255 proceedings invoked Rule 60(b)(6), but his motion sought reopening based on a 'mistake' covered by Rule 60(b)(1).
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Why Judicial Review is relevant to Kemp v. United States
The case involves the Court's interpretation and application of federal procedural rules, which is an exercise of judicial review over lower court decisions.
Syllabus excerpt (verbatim)Held: The term 'mistake' in Rule 60(b)(1) includes a judge's errors of law.
Key Quotes
Short excerpts from the syllabus in Kemp v. United States that support the summary and concepts above.
The term 'mistake' in Rule 60(b)(1) includes a judge's errors of law.
Kemp's motion alleged such a legal error, it was cognizable under Rule 60(b)(1) and untimely under Rule 60(c)'s 1-year limitations period.
Neither the Government nor Kemp offers a reason to depart from this reading of Rule 60(b)(1).
