What constitutes a reasonable time for filing a Rule 60(b) motion? Crane-Jenkins v. Mikarose Explained

In Crane-Jenkins v. Mikarose, the Utah Court of Appeals addressed whether a Rule 60(b) motion filed 197 days after entry of a default judgment satisfied the “reasonable time” requirement. The court’s analysis provides important guidance for practitioners seeking relief from judgments under Rule 60(b).

Background and Facts

Michelle Crane-Jenkins sued her former employer Mikarose LLC for $1,000 in unpaid overtime wages. After defendants failed to timely answer the complaint, the district court entered a default judgment on December 9, 2013. Defendants retained multiple attorneys over several months, with their final counsel filing a Rule 60(b) motion under subsections (4) and (6) on June 25, 2014—197 days after the default judgment. The district court denied the motion as untimely.

Key Legal Issues

The central issue was whether defendants’ Rule 60(b) motion was filed within a “reasonable time” as required by subsections (4) and (6). The court also considered whether counsel’s alleged gross negligence could excuse the delay under the Menzies v. Galetka standard.

Court’s Analysis and Holding

The Court of Appeals applied an abuse of discretion standard and affirmed the district court’s denial. The court emphasized that reasonable time “depends upon the facts of each case,” considering factors including finality interests, reasons for delay, practical ability to learn of grounds for relief, and prejudice to other parties. Unlike cases where parties lacked notice of judgments, defendants here had timely notice and reason to expect a default judgment, yet failed to act diligently. The court distinguished Menzies, noting that subsequent cases have “essentially limited Menzies to its facts” involving capital cases with extreme attorney misconduct.

Practice Implications

This decision underscores that courts will closely scrutinize delays in filing Rule 60(b) motions, particularly when parties had notice of adverse judgments. The “gross negligence” exception from Menzies remains extremely limited and typically applies only in capital cases with extraordinary circumstances. Practitioners must act diligently once grounds for relief become apparent and should not rely on attorney negligence as grounds for excusing procedural delays in civil cases.