In a decision with sweeping legal implications, the U.S. Supreme Court ruled Wednesday that voluntarily dismissed lawsuits can still be eligible for special judicial relief and reopening, even if a statute of limitations would ordinarily bar them.
The unanimous ruling in Waetzig v. Halliburton Energy Services overturned a Tenth Circuit decision that had denied ex-Halliburton account leader Gary Waetzig the chance to revive his age discrimination case. The court found that voluntarily dismissed cases qualify as “final proceedings,” making them subject to review under Federal Rule of Civil Procedure 60.
A Legal Loophole or a Necessary Correction?
Writing for the court, Justice Samuel Alito dismissed concerns that voluntary dismissals fall into a “procedural no-man’s-land,” neither interlocutory nor final. Instead, he emphasized that Rule 60(b) allows courts to grant relief from a “final judgment, order, or proceeding”—a category that, in the justices’ view, includes voluntary dismissals.
“The term ‘final’ does not exclude voluntary dismissals without prejudice from the reach of the rule,” Alito wrote. “There is no reason to think that such dismissals have since escaped the rule’s coverage.”
The ruling directly benefits Waetzig, who sued Halliburton for age discrimination after being fired at age 66. Halliburton countered by enforcing an arbitration agreement, leading Waetzig to voluntarily dismiss his case. However, after losing in arbitration and challenging its fairness, Waetzig attempted to return to court—only to find himself barred by a statute of limitations. A district court allowed him to revive the case under Rule 60, but the Tenth Circuit reversed that decision, setting the stage for the Supreme Court showdown.
