Lili Wan filed a negligence complaint in Delaware state court alleging injury caused by a truck driver employed by Central Transport LLC. The case was removed to federal court, where Central Transport moved for summary judgment. Wan submitted a one-page, unsworn response that reiterated her claims but included no evidentiary material. The District Court granted summary judgment for the defendant, and the Third Circuit previously affirmed that ruling on direct appeal, noting that courts are not obligated to consider evidence not presented by the party. Wan subsequently filed a motion for relief from judgment under Federal Rule of Civil Procedure 60(b), which the District Court denied. She also filed a motion for reconsideration, which was denied, prompting this appeal.
The Third Circuit reviewed the denial of the Rule 60(b) motion for abuse of discretion. Wan argued that her failure to submit evidence constituted 'excusable neglect' under Rule 60(b)(1) because the District Court failed to provide her with legal guidance on how to oppose a summary judgment motion. The court rejected this, reiterating that pro se litigants are not entitled to 'how-to legal manuals' from the Court and must 'abide by the same rules that apply to all other litigants.' The court noted that ignorance of the rules or mistakes in construing them do not usually constitute excusable neglect. Regarding her claim under Rule 60(b)(2) for newly discovered evidence, the court applied the standard that such evidence must be material, could not have been discovered earlier with reasonable diligence, and would probably have changed the outcome. The court found that Wan was aware of the police report during discovery but failed to seek an extension of time to obtain it. Furthermore, the police report did not provide independent evidence of the defendant's breach of care, meaning it would not have changed the outcome of the summary judgment motion.
The District Court's original grant of summary judgment in favor of Central Transport LLC remains intact. The decision reinforces that pro se litigants bear the same burden as represented parties to comply with procedural rules and cannot rely on the court to provide legal instruction. It clarifies that evidence known during the discovery phase but not submitted in time cannot be introduced later under the guise of newly discovered evidence if it would not alter the result.
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