Fafel v. DiPaola

LIPEZ, Circuit Judge.

Plaintiff-Appellant Leonard Fafel appeals from the denial of his Rule 60(b)(4) motion for relief from an injunction that prohibits him from pursuing claims in state court in contravention of a consent judgment entered in federal court pursuant to Rule 68. See Fed.R.Civ.P. 60 (Relief from Judgment or Order); Fed.R.Civ.P. 68 (Offer of Judgment). Fafel argues that the injunction is void for lack of subject-matter jurisdiction because the district court misunderstood the scope of its ancillary jurisdiction to enforce the underlying Rule 68 judgment. Given that the district…