Hadges v. Yonkers Racing Corporation

United States Court of Appeals for the Second Circuit · 1995 · Civil Procedure

48 F.3d 1320 (2d Cir. 1995)

Updated July 29, 2026

Civil ProcedureRule 60(b)Rule 11 Sanctionsfraud on the courtindependent actionRule 11safe harborseparate motion requirement

Facts

After Yonkers Racing Corp. barred Hadges from working at Yonkers Raceway, Hadges previously sued under § 1983 and lost in Hadges I, where YRC had submitted an affidavit stating that the ban did not prevent him from working at other tracks, including the Meadowlands. In a later suit against the Meadowlands, Meadowlands submitted an affidavit stating that in 1992 it banned Hadges based on the Yonkers ban and a 1992 resolution excluding persons ruled off another racetrack. Hadges then brought an independent Rule 60(b) action claiming YRC's earlier affidavit was a fraud on the court. In that Rule 60(b) action, Hadges also submitted statements suggesting he had not worked for more than four years and misstated the date of a scratching incident, which led the district court to sanction both him and his lawyer under Rule 11.

Issue

Did the district court abuse its discretion by denying independent Rule 60(b) relief on the ground that YRC committed fraud on the court in Hadges I? Did the district court abuse its discretion by imposing Rule 11 sanctions on Hadges and censuring Kunstler under the 1993 version of Rule 11?

Rule

Under Rule 60(b)'s savings clause, an independent action for fraud on the court is available, but the fraud required is narrower than ordinary fraud under Rule 60(b)(3): it must seriously affect the integrity of the normal process of adjudication and include only fraud that defiles the court itself or prevents the judicial machinery from performing its impartial task. Under the 1993 version of Rule 11, sanctions sought by motion must be made separately and served at least 21 days before filing to provide a safe harbor for withdrawal or correction; monetary sanctions may not be imposed on a represented party for frivolous legal contentions; and a court acting on its own initiative must issue a specific show-cause order. For attorney factual representations, the question is whether, after an inquiry reasonable under the circumstances, the factual contentions had evidentiary support, and an attorney may rely on a client's objectively reasonable factual statements.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In 2021, a private security contractor in Cleveland submitted an affidavit in federal court stating that Dana Ruiz could still obtain similar work from other firms in Ohio despite being barred from one jobsite. Dana lost the suit. In 2024, a different company in Columbus adopted a new policy refusing to hire anyone excluded by Dana's former contractor and denied her work under that new policy.

Dana brings an independent action seeking to vacate the 2021 judgment for fraud on the court. Which is the strongest argument against relief?

Explanation. An independent action for fraud on the court remains available beyond one year, but the fraud required is much narrower than ordinary fraud. It must seriously affect the integrity of the adjudicative process. A later action by a different entity under a later-adopted policy does not itself prove the earlier statement was false when made, much less establish fraud on the court.