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.
