First Circuit: Giroux v. Federal National Mortgage

FRCP

Court does not violate the FRCP by summary denial of a 60(b) motion.

New evidence that is merely cumulative to past assertions is not a basis for a 60(b)2 motion.

Fraud in the foreclosure is distinct from fraud in the litigation, and therefore not a basis for a 60(b)3 motion.

Except in cases of willful default, a summary denial of a 60(b)6 motion on res judicata grounds doesn't violate the FRCP.

http://media.ca1.uscourts.gov/pdf.opinions/15-1270P-01A.pdf