Case Activity (185)

1. Filed: June 10, 2026 | Entered: June 10, 2026 Hoffman et al v. Brefko Group LLC et al

   190 Contract: Other | Illinois Northern

   Minute

   MINUTE entry before the Honorable Thomas M. Durkin: On July 16, 2024, the Court granted an unopposed motion to enforce a settlement agreement and entered a judgment order that made Defendant Chest Ties, its owner Chukwuemeka Anarah, and nonparty Emmanuel Akachukwu jointly and severally liable to Plaintiffs in the amount of $70,000. R. 72. On November 19, 2025, Akachukwu moved to vacate that order pursuant to Federal Rule of Civil Procedure 60(b)(3) arguing that Plaintiffs misrepresented him as an agent of Chest Ties in seeking to enforce the settlement agreement against him. R. 106. That motion is denied as untimely because it was filed more than one year after the Court entered the judgment order. See Fed. R. Civ. P. 60(c)(1) (requiring that a Rule 60(b)(3) motion be made "no more than a year after entry of the judgment or order"); Arrieta v. Battaglia, 461 F.3d 861, 864 (7th Cir. 2006) ("This time limit is jurisdictional and cannot be extended."). However, because Akachukwu is not a party to this litigation, the judgment order is void as to him for lack of jurisdiction. See Fed. R. Civ. P. 60(b)(4); see also Philos Techs., Inc. v. Philos & D, Inc., 645 F.3d 851, 855 (7th Cir. 2011) ("A judgment entered against a defendant over whom the court had no jurisdiction is void, and no court has the discretion to refuse to vacate that judgment once it recognizes its lack of jurisdiction."). Plaintiffs' claim that Akachukwu is an agent of Chest Ties does not change this analysis because Akachukwu remains a nonparty. See Zenith Radio Corp. v. Hazeltine Research, Inc., 395 U.S. 100, 111 (1969) (finding that whether a nonparty is the "alter ego" of a defendant can't be properly litigated absent the nonparty's "appearance before judgment with full opportunity to contest jurisdiction"). Therefore, the judgment order 72 is hereby vacated as to Akachukwu. See Mendez v. Republic Bank, 725 F.3d 651, 660 (7th Cir. 2013) (permitting district courts to correct clear errors before an appeal through Rule 60(b)); Judson v. Atkinson Candies, Inc. v. LatiniHohberger Dhimantec, 529 F.3d 371, 385 (7th Cir. 2008) (recognizing that a majority of circuits have held that a court may sua sponte vacate a judgment or order under Rule 60(b)). Plaintiffs briefly request leave to amend their complaint to add Akachukwu as a defendant. That request is denied without prejudice. Plaintiffs may renew that request as part of a separate motion to the Court. Mailed notice. (ecw, ) (Entered: 06/10/2026)

2. Filed: June 10, 2026 | Entered: June 10, 2026 Hoffman et al v. Brefko Group LLC et al

   190 Contract: Other | Illinois Northern

   Amedned

   AMEDNED Judgment Order. Signed by the Honorable Thomas M. Durkin on 6/10/2026. Mailed notice. (ecw, ) (Entered: 06/10/2026)

3. 183 additional result(s)