Horne v. Flores
Supreme Court
129 S.Ct. 2579 (2009)
After a district court found Arizona officials (defendants) violated the Equal Educational Opportunities Act by underfunding English Language Learner programs and ordered increased funding, years of subsequent litigation, legislative involvement, and passage of the federal No Child Left Behind Act followed. The state defendants sought relief from the ongoing injunction under Rule 60(b)(5), arguing continued enforcement was no longer equitable, but the district court and court of appeals denied relief largely because the state still hadn't allocated funds meeting the original order's specific demands.
Whether a party may obtain relief from a judgment under Rule 60(b)(5) when continued enforcement is no longer equitable, even where the underlying conditions triggering the injunction have not been remedied in the exact way originally ordered.