Burnett v. District Court of Maryland

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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
JEROME ANDREW BURNETT,
Plaintiff,
v.
DISTRICT COURT OF MARYLAND,
#10-02,
Defendant.
Case No. 25-cv-1291-ABA
MEMORANDUM OPINION AND ORDER
Plaintiff Jerome Burnett has filed a motion for reconsideration of this Court’s
August 4, 2025 order dismissing his complaint and several other related motions. For
the following reasons, the Court will deny Burnett’s motion for reconsideration and
deny the other motions as moot.
I. 	BACKGROUND
Burnett’s complaint, which was filed in April 2025, brought statutory and
constitutional claims against the District Court of Maryland for Carroll County. ECF No.
1 at 6. This Court dismissed the complaint on August 4, 2025 for two reasons. First, the
Court dismissed Burnett’s claims under 42 U.S.C. § 1983 because state courts and
agencies are not amenable to such claims. ECF No. 26 at 2. Second, the Court dismissed
Burnett’s remaining claims under Federal Rule of Civil Procedure 8(a) for failure to
“provide simple, concise factual allegations that show a connection between the District
Court’s actions and the alleged wrongdoing.” Id. at 3. This dismissal was also on subject
matter jurisdiction grounds, because Burnett failed to plead any cognizable violation of
federal law or diversity of citizenship. Id. Burnett filed a motion for reconsideration on
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August 8, 2025. ECF No. 27. Mr. Burnett has also filed a motion to issue summons (ECF
No. 28), two supplements to his complaint (ECF Nos. 29 and 30), a supplement to his
motion for reconsideration (ECF No. 32), a motion to compel (ECF No. 33), and a
motion to enforce judgment (ECF No. 34).
II. 	DISCUSSION
Burnett’s motion for reconsideration is difficult to follow, but refers to both Rule
59(e) and Rule 60. ECF No. 27 at 2. The Court remains mindful of its obligation to
liberally construe the pleadings and papers of self-represented litigants, see Erickson v.
Pardus, 551 U.S. 89, 94 (2007), but, even so, Burnett is not entitled to relief under
either Rule 59 or Rule 60.
A. 	Rule 59(e)
Rule 59(e) allows for a “motion to alter or amend a judgment.” Fed. R. Civ. P.
59(e). “It is an extraordinary remedy that should be applied sparingly.” Mayfield v. Nat'l
Ass’n for Stock Car Auto Racing, Inc., 674 F.3d 369, 378 (4th Cir. 2012). A “Rule 59(e)
motion ‘need not be granted unless the district court finds [1] that there has been an
intervening change of controlling law, [2] that new evidence has become available, or [3]
that there is a need to correct a clear error or prevent manifest injustice.’” Nicholson v.
Durant, -- F.4th ---, Case No. 24-1789, 2025 WL 3674710, at *3 (4th Cir. Dec. 18, 2025)
(quoting Robinson v. Wix Filtration Corp. LLC, 599 F.3d 403, 411 (4th Cir. 2010)).
Burnett has not shown an entitlement to relief on any of these three grounds.
Burnett does not cite any intervening change of law. Although Burnett has provided
what he characterizes as supplements to the complaint, ECF Nos. 29 and 30, which the
Court has reviewed, neither of these documents contains any new evidence. And even if
the Court were to allow Burnett to incorporate these supplements into his complaint
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retroactively, the supplements would not change the analysis in the Court’s original
opinion dismissing the case. They still fail to contain short and plain allegations of fact
explaining why Burnett is entitled to relief. Burnett’s motion also fails to explain why the
Court’s prior opinion contains a clear error or must be amended to prevent manifest
injustice. Instead, to the extent the motion to reconsider makes any argument, it
appears Burnett simply disagrees with the previous opinion. But “[m]ere disagreement
does not support a Rule 59(e) motion.” Nicholson, 2025 WL 3674710, at *3 (quoting
Hutchinson v. Staton, 994 F.2d 1076, 1081–82 (4th Cir. 1993)). To the extent Burnett
has moved under Rule 59(e), his motion is denied.
B. 	Rule 60(b)
Burnett’s argument fares no better under Rule 60. Burnett’s motion cites Rule 60
generally. Rule 60(a), which pertains to “clerical mistakes” and related errors, is not
implicated here. Rule 60(b) allows a court to “relieve a party . . . from a final judgment,
order, or proceeding” for one of six reasons:
1. 	mistake, inadvertence, surprise, or excusable neglect;
2. 	newly discovered evidence that, with reasonable
diligence, could not have been discovered in time to move
for a new trial under Rule 59(b);
3. 	fraud (whether previously called intrinsic or extrinsic),
misrepresentation, or misconduct by an opposing party;
4. 	the judgment is void;
5. 	the judgment has been satisfied, released, or discharged;
it is based on an earlier judgment that has been reversed
or vacated; or applying it prospectively is no longer
equitable; or
6. 	any other reason that justifies relief.
Fed R. Civ. P. 60(b). “[T]o obtain relief from a final judgment under Rule 60(b), one of
the six grounds enumerated must be satisfied.” Daulatzai v. Maryland, 97 F.4th 166,
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178 (4th Cir. 2024). “Like a 59(e) motion, Rule 60 provides for an extraordinary remedy
that should not be awarded except under exceptional circumstances.” Mayfield, 674
F.3d at 378.
Burnett’s motion has not satisfied any of these six factors. His motion does not
coherently explain how any of the first five factors would apply. The Court’s own review
of the prior opinion and Burnett’s submissions does not reveal any basis for relief on the
first five grounds either. Although Rule 60(b)(6) provides a “catchall” basis, it requires
“a showing of ‘extraordinary circumstances’” to warrant relief. Daulatzai, 97 F.4th at
178 (quoting Kemp v. United States, 596 U.S. 528, 533 (2022)). Burnett has not made a
showing of extraordinary circumstances, and has not explained why he is entitled to
relief from the prior order. His motion will be denied to the extent it moves for relief
under Rule 60(b).
III. 	CONCLUSION AND ORDER
For the foregoing reasons, it is hereby ORDERED as follows:
1. 	Plaintiff’s motion for reconsideration (ECF No. 27) is DENIED.
2. 	Plaintiff’s other motions (ECF Nos. 28, 33, and 34) are DENIED as moot.
3. 	The Clerk of Court is directed to mark this case as CLOSED.
Date: January 22, 2026
Adam B. Abelson
United States District Judge
/s/
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