United States v. Beggerly - 524 U.S. 38 (1998)

I Issue
Whether P's complaint meets the language of FRCP 60.
II. Fact
In 1979, the federal government brought a title action against Beggerly.  They settled.  Judgment was entered based on this settlement agreement.  In 1994, armed with new information, Beggerly sued to obtain a damage award for the disputed land.  The District Court concluded that it was without jurisdiction to hear D's suit and dismissed the complaint.  The court of Appeals reversed, reasoning that the suit satisfied the elements of an "independent action," as the term is used in FRCP 60(b).
III. Holding
The sense of these expressions is that an independent action should be available only to prevent a grave miscarriage of justice.  In this case, it should be obvious that P's allegations do not nearly approach the demanding standing.  P alleges only that the United States failed to "thoroughly search its records and make full disclosure to the Court."  There was a insufficient basis to justify the reopening of the judgment in the previous litigation.