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defendantjurisdictionlitigationinjunctionappealtrialmotionwilldue processpiracy
jurisdictioninjunctionappealmotionwillcorporationpiracy

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United States v. Philip Morris USA Inc., 840 F.3d 844, 426 U.S.App.D.C. 269, 95 Fed.R.Serv.3d 2000, RICO Bus.Disp.Guide 12,788

Facts

In 1999, the United States sued R.J. Reynolds and other cigarette manufacturers under RICO, alleging a conspiracy to mislead the public about smoking dangers. After a lengthy trial, the district court found the defendants liable and ordered them to run corrective advertisements. R.J. Reynolds later merged with Brown & Williamson and contested the requirement to run ads as both an original defendant and a successor, leading to further litigation over the injunction's validity.

In 1999, the United States sued RJR, Brown & Williamson Tobacco Corporation, and several other cigarette manufacturers under the Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. §§ 1961 – 68, alleging a conspiracy to deceive the American public about the dangers of cigarettes.

Issue

Did the district court err in denying R.J. Reynolds' motion for relief from the injunction requiring it to run corrective advertisements as both an original defendant and a successor?

RJR argues, as it did in the district court, that the order requiring it to run ads as Brown & Williamson's successor is void under Rule 60(b)(4) because it is punitive rather than preventive, and thus exceeds the district court's RICO authority.

Rule

Relief under Rule 60(b)(4) is available only in cases of jurisdictional error or due process violations, while Rule 60(b)(6) allows for relief for any other justifiable reason, requiring extraordinary circumstances.

Rule 60(b)(4) authorizes relief from a final order if 'the judgment is void.' Fed. R. Civ. P. 60(b)(4).

Analysis

The Court of Appeals determined that R.J. Reynolds' arguments did not demonstrate a jurisdictional error or due process violation that would render the injunction void. The court emphasized that the district court had the authority to impose the remedial order under RICO, and R.J. Reynolds' failure to timely challenge the double-ad requirement undermined its claim for relief under Rule 60(b)(6).

In our view, however, mere use of the word 'jurisdiction' is insufficient to turn a remedial error into a basis for Rule 60(b)(4) relief. As the Supreme Court has made clear, jurisdiction is 'a word of many, too many, meanings,' Steel Co., 523 U.S. at 90, 118 S.Ct. 1003—a proposition all too evident in this case.

Conclusion

The Court of Appeals affirmed the district court's decision, concluding that the injunction was valid and that R.J. Reynolds' motion for relief was denied appropriately.

For the foregoing reasons, we affirm.

Who won?

The United States prevailed in the case, as the court upheld the validity of the injunction requiring corrective advertisements, reinforcing the government's position on public health disclosures.

The Court of Appeals, Tatel, Circuit Judge, held that: 1 it had jurisdiction over manufacturer’ interlocutory appeal from denial of its motion for relief from injunction; 2 injunction was not void, despite contention it exceeded district court's remedial jurisdiction to prevent RICO violations; and 3 there were no extraordinary circumstances warranting relief from injunction on other grounds.

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