US v. People First of Tennessee, 09-5474, concerned a challenge to the district court’s denial of the State of Tennessee’s motion under Fed. R. Civ. Proc. 60(b)(5), requesting the court to vacate the injunctive relief and dismiss the case, in a case arising from the district court’s original 1993 ruling that the state was violating the substantive due process rights of mentally retarded residents at a state operated home for mentally retarded individuals.  In affirming, the court held that the state has not put forward a single case or statute that could qualify as the significant change in law required to satisfy its initial burden under Rufo v. Inmates of Suffolk County Jail, 502 U.S. 367 (1992), and in light of this failure, the district court did not abuse its discretion when it refused to revisit the original judgment.

Traverse Bay Area Intermediate Sch. Dist. v. Michigan Dep’t of Educ., 08-1228, involved a school district’s suit against various state agencies, for the alleged failure to maintain procedural due process protections in accordance with the Individuals with Disabilities in Education Act (IDEA).  In affirming the district court’s dismissal of plaintiff’s amended complaint, the court held that the IDEA does not provide school districts with an express or implied right to compel state defendants’ compliance with section 1415(b)’s procedural safeguards absent an underlying claim that directly involves a disabled child’s individual educational program (IEP).

Pinchon v. Myers, 07-6496, concerned a challenge to the dismissal of defendant’s claims in habeas proceedings of a defendant convicted of first degree murder of his adult male lover and sentenced to life in prison (defendant was seventeen at the time of his arrest and tried as an adult).  In affirming, the court held that the district court did not err in concluding that defendant’s amended petition was untimely because his ineffective assistance of counsel claims do not relate back to his original petition.  Further, the court held that defendant failed to timely raise his claim that the district court erred in concluding that his ineffective assistance claim was procedurally defaulted and, that defendant has not shown that the jury’s verdict was an unreasonable determination in light of the evidence presented at trial, nor has he shown that the state court’s decision was contrary to, or an unreasonable application of, clearly established federal law.

Related Resources:

  • Full text of US v. People First of Tennessee
  • Full text of US v. Barr
  • Full text of Traverse Bay Area Intermediate Sch. Dist. v. Michigan Dep’t of Educ
  • Full text of Pinchon v. Myers

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