Background
Maheswar Mikkilineni sued PayPal, GoDaddy, Upwork, Shijil TS/SparkSupport Infotech Pvt. Ltd., and entities associated with the Harvard Smithsonian Center for Astrophysics. He alleged that the defendants had obstructed his efforts to host, encode, and expand a website intended to commercialize his scientific and religious views about the universe’s atomic underpinnings.
After the federal district court dismissed the claims against the Harvard-affiliated defendant on sovereign-immunity grounds and remanded the case, the Superior Court dismissed the claims against PayPal, GoDaddy, and Upwork in 2021. In September 2025, it dismissed the remaining claims against Spark under Superior Court Civil Rule 41(e) because Mikkilineni had failed to prosecute them diligently. He did not appeal that final order, instead moving under Rule 60(b)(6) to set it aside as a purported fraud upon the court. The Superior Court denied the motion, and Mikkilineni appealed.
The Court’s Holding
The Delaware Supreme Court affirmed. It explained that an appeal from the denial of a Rule 60(b) motion permits review only of that denial, not of alleged errors in the underlying judgment that could have been raised through a timely direct appeal. Mikkilineni therefore could not use the Rule 60 proceedings to challenge the Superior Court’s 2021 and 2025 dismissal rulings.
The court also concluded that Mikkilineni did not argue that the Superior Court had abused its discretion in denying Rule 60(b)(6) relief. The record, moreover, showed no fraud upon the court or other circumstance satisfying Rule 60(b)(6)’s exacting standard. The court separately denied PayPal’s motion for attorney’s fees and costs under Delaware Supreme Court Rule 20(f).
Key Takeaways
- A Rule 60(b) motion cannot substitute for a timely appeal from the underlying judgment.
- Appellate review of an order denying Rule 60(b) relief is limited to whether the trial court abused its discretion in denying that relief.
- The record did not establish fraud upon the court or another basis for extraordinary relief under Rule 60(b)(6).
- Although it affirmed the judgment, the court declined to award PayPal attorney’s fees or costs.
Why It Matters
The order reinforces the procedural boundary between a direct appeal and a motion for relief from judgment. A litigant who allows the appeal period to expire generally cannot revive challenges to the merits of the judgment by recasting them as a Rule 60(b)(6) claim.
It also illustrates that affirmance does not automatically entitle an appellee to sanctions or fee-shifting: the court rejected PayPal’s request for fees and costs despite upholding the denial of post-judgment relief.