In 2022, Constantine Ananiades filed a lawsuit in the United States Court of Federal Claims alleging takings and breach-of-contract claims against the United States government. These claims stemmed from a physical container he submitted to the Department of the Air Force in 1984. The Court of Federal Claims dismissed the complaint for lack of subject matter jurisdiction, ruling that the six-year statute of limitations under 28 U.S.C. § 2501 barred the claims. The Federal Circuit previously affirmed that dismissal. After the mandate issued, Ananiades filed multiple motions for relief from judgment and reconsideration in the Court of Federal Claims under various sections of Rule 60(b), all of which were denied. The most recent denial occurred in May 2025, prompting this appeal.
The Federal Circuit reviewed the Court of Federal Claims' denial of the Rule 60(b)(6) motion for abuse of discretion. Under RCFC 60(b)(6), a court may relieve a party from a final judgment only for extraordinary circumstances. The court noted that the lower court correctly identified that Ananiades' renewed motion did not present such circumstances but instead attempted to relitigate the dismissal of his case. The lower court found that Ananiades was challenging the court's treatment of his allegations, the standard of review, and the application of timing rules, which amounted to an attempt to retry the case after he had already been afforded a full and fair opportunity to do so. The Federal Circuit emphasized that an appeal from the denial of a Rule 60(b)(6) motion does not reopen the underlying decision for review. Since Ananiades raised previously litigated issues and provided no basis to conclude the lower court abused its discretion, the appellate court found no grounds to reverse.
The decision affirms the finality of the dismissal of Ananiades' claims, leaving the six-year statute of limitations as an absolute bar to his takings and contract claims against the government. The ruling reinforces that Rule 60(b)(6) is reserved for extraordinary circumstances and cannot be used as a vehicle to relitigate cases that have already been decided on the merits or procedural grounds like the statute of limitations. No further action is required by the government, and the case remains closed.
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