The Washington Supreme Court reversed the Court of Appeals and granted extraordinary relief under Civil Rule 60(b)(11) in *Luv v. West Coast Servicing, Inc.*, No. 103031-2, concluding that a trial court abused its discretion by applying the wrong legal standard and that a series of legal mistakes justified relief from judgment.
The case, decided en banc on October 9, 2025, originated from what Justice Johnson described as "a trial court's erroneous application of law." The complex procedural history demonstrates the challenges parties face when seeking post-judgment relief after multiple levels of appellate review have already occurred.
Initially, the trial court made what the Supreme Court characterized as an erroneous application of law in favor of one party. When the losing party appealed that decision, the Court of Appeals affirmed the trial court's ruling on initial appeal. The Washington Supreme Court then denied review of the Court of Appeals decision, seemingly ending the matter through the normal appellate process.
However, the losing party pursued an alternative remedy by returning to the trial court and seeking relief under Civil Rule 60(b)(11), which allows courts to "relieve a party or the party's legal representative from a final judgment, order, or proceeding for any other reason justifying relief from the operation of the judgment." This catch-all provision serves as a safety valve for extraordinary circumstances that don't fit within the more specific grounds for relief outlined in other subsections of the rule.
The trial court denied the motion for relief under CR 60(b)(11). The disappointed party then appealed that denial to the Court of Appeals, which also denied relief. This created a situation where the original erroneous ruling had been affirmed twice and relief had been denied twice, despite what the Supreme Court ultimately concluded was a clear legal error.
The Washington Supreme Court's intervention represents the final word on the matter, with the state's highest court concluding that "the trial court abused its discretion by applying the wrong legal standard under CR 60(b)(11)." This language indicates that the trial court not only reached the wrong result but did so by using an incorrect analytical framework for evaluating whether extraordinary relief was warranted.
Justice Johnson, writing for the court, emphasized that "the series of legal mistakes combined with the other circumstances in this case satisfy CR 60(b)(11), justifying relief from judgment." This formulation suggests that the court considered not just the initial trial court error, but the cumulative effect of multiple procedural missteps throughout the litigation.
The decision provides important guidance for practitioners regarding when Civil Rule 60(b)(11) relief may be appropriate. Unlike the more specific grounds for relief outlined in other subsections of CR 60(b), such as newly discovered evidence or fraud, subsection (11) requires courts to engage in a more flexible analysis of whether extraordinary circumstances justify setting aside a final judgment.
The case name indicates that Prince Eric Luv was the respondent and West Coast Servicing, Inc. was the petitioner before the Supreme Court, suggesting that West Coast Servicing was the party seeking relief from an adverse judgment. The fact that the Supreme Court sided with West Coast Servicing indicates that the company successfully demonstrated that the original trial court ruling was so fundamentally flawed that extraordinary relief was warranted despite the passage of time and multiple layers of appellate review.
The en banc designation means that all justices of the Washington Supreme Court participated in the decision, rather than a smaller panel. This designation often signals that the court viewed the case as presenting particularly important legal questions or that the issues were sufficiently complex to warrant input from the full court.
The timing of the decision, filed in October 2025, suggests that this case had been working its way through the court system for an extended period, given the multiple levels of proceedings described in the opinion. The procedural complexity demonstrates how post-judgment relief motions can extend litigation significantly beyond the normal appellate process.
For legal practitioners, the decision reinforces that CR 60(b)(11) remains a viable option for seeking relief from judgments in extraordinary circumstances, even after appellate review has been exhausted. However, the high bar suggested by the "series of legal mistakes" language indicates that isolated errors are unlikely to justify such relief absent other compelling circumstances.
The reversal of the Court of Appeals also highlights the Washington Supreme Court's willingness to exercise its discretionary jurisdiction to correct what it views as fundamental errors in the application of procedural rules, even in cases that may not present issues of broad public importance.