Waetzig v. Halliburton Energy Services, Inc.
View Official PDFSummary
A short, plain-English overview of Waetzig v. Halliburton Energy Services, Inc..
In Waetzig v. Halliburton Energy Services, Inc., the Supreme Court addressed whether a case voluntarily dismissed without prejudice under Rule 41(a) qualifies as a 'final proceeding' under Rule 60(b). The Court concluded that such a dismissal is indeed 'final' because it terminates the case, aligning with the historical and textual understanding of the term. The decision reversed the Tenth Circuit's ruling and remanded the case for further proceedings.
Holding
The single most important “bottom line” of what the Court decided in Waetzig v. Halliburton Energy Services, Inc..
The Court held that a case voluntarily dismissed without prejudice under Rule 41(a) counts as a 'final proceeding' under Rule 60(b).
Key Quotes
Short excerpts from the syllabus in Waetzig v. Halliburton Energy Services, Inc. that support the summary and concepts above.
A voluntary dismissal is 'final' because it terminates the case.
The structure of the Rule suggests that each term should be read as broader than what came before.
Rule 60(b) was modeled after a California statute previously interpreted to extend to voluntary dismissals without prejudice.
