| Venue: | SCOTUS |
| Facts: | There was some litigation about who might have owned some lands involved in the LA purchase. It settled, but subsequently Beggerly found some info in the national archives that tended to establish a stronger claim, which would have entitled her to lots more. |
| Posture: | Suit in district court, asking to set aside the prior settlemend and award famages. Dismissed for lack of jurisdiction. Reversed on appeal, saying that thtis fits the "independent action" criteria in rule 60(b). |
| Issue: | Did the court of appeals err in concluding that it had jurisdiction over the new suit? |
| Holding: | Yes. Reversed. |
| Rule: | An independent action is only available to prevent a grave miscarriage of justice. |
| Reasoning: | The evidence was available previously; she just didn't find it.
And she got some settlement previously. This just isn't grave. |
| Dicta: | |