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.

Corporate Fears vs. Access to Justice

Halliburton and its allies, including the U.S. Chamber of Commerce, warned that the ruling could unleash a wave of “litigation gamesmanship.” The Chamber painted a grim picture in its amicus brief, arguing that under Waetzig’s interpretation, even multimillion-dollar class actions could be voluntarily dismissed, only to be resurrected years later after statutes of limitations expired—causing legal uncertainty for businesses.

“This shouldn’t be allowed,” the Chamber contended, calling Waetzig’s position a “perverse interpretation” that could allow long-dormant cases to be revived indefinitely.

Waetzig countered that a ruling against him would create a “twilight zone” in which courts would be powerless to correct mistakes and fraud. His argument swayed the justices, who unanimously sided with him in finding that voluntary dismissals still qualify for judicial relief under Rule 60.

Victory for Waetzig—But the Fight Isn’t Over

Despite Wednesday’s ruling, Waetzig’s battle with Halliburton is far from settled. The Supreme Court’s 2022 decision in Badgerow v. Walters complicates his path forward. That ruling held that federal courts cannot vacate arbitration awards unless an independent jurisdictional basis exists beyond the Federal Arbitration Act.

During oral arguments, Halliburton heavily leaned on Badgerow, and Justice Elena Kagan—who authored that decision—noted that Waetzig would “have a tough row to hoe” on that issue. Even with this Supreme Court victory, his ability to ultimately challenge the arbitration decision remains uncertain.

Legal Representation

Waetzig is represented by Holwell Shuster & Goldberg LLP and Kontnik Cohen LLC.

Halliburton is represented by Gibson Dunn & Crutcher LLP and The Kullman Firm PLC.