United States v. Beggerly

What the Court Decided

Held that independent actions under Rule 60(d) are available only in cases of grave injustice and are not a routine alternative to Rule 60(b) motions.

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Cited In

Coney Island Auto Parts Unlimited v. Burton

2025 Term · 24-808

Cited by respondent for the proposition that Rule 60(d) independent actions are reserved to correct only gross miscarriages of injustice, limiting the availability of that alternative relief mechanism.