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Waetzig v. Halliburton Energy Services

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Supreme Court of the United States
Waetzig v. Halliburton Energy Services
Term: 2024
Important Dates
Argued: January 14, 2025
Decided: February 26, 2025
Outcome
reversed and remanded
Vote
9-0
Majority
Samuel Alito • Chief Justice John Roberts • Clarence Thomas • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Brett Kavanaugh • Amy Coney Barrett • Ketanji Brown Jackson

Waetzig v. Halliburton Energy Services is a case that was decided by the Supreme Court of the United States on February 26, 2025, during the court's October 2024-2025 term. The case was argued on January 14, 2025.

The Court reversed and remanded the decision of the United States Court of Appeals for the Tenth Circuit in a 9-0 ruling, holding that a "case voluntarily dismissed without prejudice under Rule 41(a) counts as a “final proceeding” under Rule 60(b)." Justice Samuel Alito delivered the majority opinion of the court.[1] Click here for more information about the ruling.

HIGHLIGHTS
  • The issue: The case concerned whether a voluntary dismissal, as outlined in Federal Rule of Civil Procedure Rule 41(a), qualifies as a “final judgment, order, or proceeding,” as described in Fed. R. Civ. P. Rule 60(b). Click here to learn more about the case's background.
  • The questions presented: "Whether a Rule 41 voluntary dismissal without prejudice is a 'final judgment, order, or proceeding' under Rule 60 (b)."[2]
  • The outcome: The Court reversed and remanded the decision of the lower court in a 9-0 ruling.


    • The case came on a writ of certiorari to the United States Court of Appeals for the Tenth Circuit. To review the lower court's opinion, click here.

    Background

    Case summary

    The following are the parties to this case:[3]

    • Petitioner: Gary Waetzig
      • Legal counsel: Vincent Gregory Levy (Holwell Shuster & Goldberg, LLP)
    • Respondent: Halliburton Energy Services, Inc.
      • Legal counsel: Matthew Dempsey McGill (Gibson, Dunn & Crutcher LLP)

    The following summary of the case was published by Oyez, a free law project from Cornell’s Legal Information Institute, Justia, and the Chicago-Kent College of Law:[4]

    “ In February 2020, Gary Waetzig sued his former employer Halliburton for age discrimination but voluntarily dismissed his suit without prejudice due to a contractual obligation to arbitrate. After an arbitrator granted summary judgment to Halliburton, Waetzig returned to federal court. Instead of filing a new complaint under the Federal Arbitration Act, he moved to reopen his original case and vacate the arbitration award. The district court agreed to reopen the case using Rule 60(b), citing Mr. Waetzig’s mistaken dismissal and an intervening Supreme Court case that affected his ability to refile. The court then vacated the arbitrator’s order, finding the arbitrator had exceeded her powers, and remanded for further proceedings before a new arbitrator. The U.S. Court of Appeals for the Tenth Circuit reversed, concluding that the Waetzig’s voluntary dismissal without prejudice was not a “final proceeding” within the meaning of Rule 60(b).[5] ”

    To learn more about this case, see the following:

    Timeline

    The following timeline details key events in this case:

    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    “ Whether a Rule 41 voluntary dismissal without prejudice is a 'final judgment, order, or proceeding' under Rule 60 (b).[5] ”

    Oral argument

    Audio

    Audio of oral argument:[7]




    Transcript

    Transcript of oral argument:[8]

    Outcome

    In a 9-0 opinion, the court reversed and remanded the judgment of the United States Court of Appeals for the Tenth Circuit, holding that a "case voluntarily dismissed without prejudice under Rule 41(a) counts as a “final proceeding” under Rule 60(b)." Justice Samuel Alito delivered the opinion of the court.[1]

    Opinion

    In the court's majority opinion, Justice Samuel Alito wrote:[1]

    “

    Federal Rule of Civil Procedure 60(b) permits a court, “[o]n motion and just terms,” to “relieve a party . . . from a final judgment, order, or proceeding.” The question in this case is whether Rule 60(b) permits a district court to reopen a case that was voluntarily dismissed without prejudice under Rule 41(a). We hold that such a dismissal counts as a “final judgment, order, or proceeding,” and thus qualifies for Rule 60(b) relief. [5]

    		”
    —Justice Samuel Alito

    Text of the opinion

    Read the full opinion here.

    October term 2024-2025

    See also: Supreme Court cases, October term 2024-2025

    The Supreme Court began hearing cases for the term on October 7, 2024. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[9]


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 Supreme Court of the United States "SUPREME COURT OF THE UNITED STATES", "WAETZIG v. HALLIBURTON ENERGY SERVICES, INC.," February 26, 2025
    2. ↑ 2.0 2.1 [United States Court of Appeals for the Tenth Circuit "U.S. Supreme Court", "23-971 WAETZIG V. HALLIBURTON ENERGY SERVICES" October 4, 2024]
    3. ↑ Supreme Court of the United States, "No. 23-971," accessed November 20, 2024
    4. ↑ Oyez, "Waetzig v. Halliburton Energy Services, Inc.," accessed November 20, 2024
    5. ↑ 5.0 5.1 5.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    6. ↑ U.S. Court of Appeals for the 10th Circuit, Waetzig v. Halliburton, decided September 11, 2023
    7. ↑ [https://www.supremecourt.gov/oral_arguments/audio/2024/23-971 Supreme Court of the United States, "Oral Argument - Audio," argued January 14, 2025 ]
    8. ↑ [https://www.supremecourt.gov/oral_arguments/argument_transcripts/2024/23-971_nmio.pdf Supreme Court of the United States, "Oral Argument - Transcript," argued January 14, 2025 ]
    9. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
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