Judge John G. Koeltl
Appellants appealed a bankruptcy court’s order denying reconsideration of its prior oral ruling. The oral ruling clarified the now-retired bankruptcy judge’s 2008 written order that her intention had been to stay the entire proceeding, rather than to simply place the objection motion and cross-motions in abeyance. Appellants argued that the oral ruling misconstrued the judge’s 2008 written order and that this constituted a “mistake” or “other reason that justifies relief” under Federal Rule of Civil Procedure 60(b). Thus, they argued that the instant bankruptcy judge erred in not granting reconsideration. District court disagreed, finding that it was not unreasonable for the prior bankruptcy judge to interpret her written order in this fashion, especially in light of the deference afforded to a bankruptcy court’s interpretation of its own orders. Moreover, district court held that the instant bankruptcy judge correctly reasoned that the prior judge had power to depart from and modify her written order if she so chose. Further, district court concluded that the prior judge had well-founded reasons to stay the entire bankruptcy proceeding pending outcome of state court litigation that would determine ownership of the subject foundation.
