March 9, 2026·2:20-cv-00163-ECM-KFP·Per Curiam·By James Taylor
The Eleventh Circuit affirmed the district court's denial of a Rule sixty motion filed by a pro se plaintiff. The court held the appeal was patently frivolous and bound by the law of the case doctrine.
This is the fourth appeal by pro se plaintiff Bernadette Dickerson in this case. A previous appeal affirmed the district court’s denial of her Rule sixty motion because she failed to prove fraud on the court by clear and convincing evidence. After that decision, she filed five more motions in the district court raising the same vague allegations before appealing the denial of her latest motion.
The court’s reasoning
The court noted that it is bound by the law of the case doctrine. The court found the motion patently frivolous because the plaintiff provided absolutely no proof to support her vague and unsubstantiated claim of fraud on the court.
What it means going forward
The judgment of the district court is affirmed, ending this specific appeal and reinforcing the finality of the prior rulings in the case.
