Plaintiffs Michael and Irene Atraqchi, proceeding pro se, appealed a district court order denying their motion to reopen a civil case. The underlying case, originally filed in the Middle District of Florida, resulted in a judgment on May 4, 2022. The plaintiffs sought to reopen the case based on newly discovered evidence and allegations of fraud, filing their motion on September 10, 2025. The district court denied the motion, and the Atraqchis appealed, arguing that the evidence was previously unavailable and that the court abused its discretion by dismissing their claims.
The Eleventh Circuit reviewed the denial of the Rule 60(b) motion for an abuse of discretion. The court explained that the purpose of Rule 60(b) is to correct obvious errors or injustices, but it is strictly bound by time limits. Under Rule 60(b)(2), a party seeking relief based on newly discovered evidence must file the motion no more than one year after the judgment. The court found the motion untimely because it was filed over three years after the May 2022 judgment. Regarding the fraud claim under Rule 60(d)(3), the court noted that such claims require clear and convincing evidence. The plaintiffs' allegations were deemed conclusory and lacked the necessary probative facts to establish fraud on the court. The court also addressed a due process argument regarding the lack of a hearing, noting that Rule 60 does not require a hearing and that the plaintiffs failed to adequately brief the issue.
The judgment from May 2022 remains in full force. The decision reinforces the strict one-year deadline for Rule 60(b)(2) motions and clarifies that conclusory fraud allegations are insufficient to reopen a case. No remand instructions were issued as the case was affirmed.