Crawford v. Andrew Systems, Inc.

Appellant challenges the district court’s holding that an unauthorized judgment does not start the clock for a Rule 59(b) motion for new trial. We hold that the 10-day period contemplated by Rule 59(b) does not begin to run until after the entry of a valid judgment and affirm the district court. 1

I. BACKGROUND

Dwayne Davis was driving a van on an interstate highway while towing an empty flat-bed trailer. The trailer separated from the van, crossed the median, and struck a vehicle traveling in the opposite direction. That automobile was occupied by Lois and Wayne Kelley and their infant…