"Vacated judgments" - must they always be the result of an appeals court decision?

I had been under the impression that ‘vacated’ judgments could arise only as a result of an appellate court’s decision. Apparently, my impression was wrong.

Specifically, in this Wiki article about about detainees at Camp Bulkeley in Guantanamo, the following statement appears:

An almost identical sentence is also found in the Wiki article on the Guantanamo Bay Naval Base:

Taken together, these statements seem to be saying that a judgment can be vacated so long as the relevant parties agree. More interestingly (at least to me), they imply that a judgment can be vacated even in the absence of the involvement, decision, and assent of a superior court.

Have I misunderstood?


Under Rule 60 of the Federal Rules of Civil Procedure, a federal district court “may relieve a party or a party’s legal representative from a final judgment, order, or proceeding” So yeah, even if a district judge enters a final judgment, it has authority to modify or vacate that judgment.

Can it be done by consent of the parties? Usually yeah. If all parties to a dispute sign a stipulation, the judge will usually “so order” it without asking a lot of questions. Especially if the United States is a party to the stipulation.

I’ve nothing to add, only thinking that (upon reading the thread title) that “Vacated Judgments” was maybe a euphemism for poop. Especially being in the quotes like that. I was disappointed to discover it is not after reading the rest of the title, but nevertheless, shall use it as such. Now, if you’ll excuse me, I have to… well, you know…

Thanks. Much obliged.

Just to make sure I understand, let me ask: In the last sentence of your first paragraph, to whom does “it” refer? The federal judge, right?

Yeah, “it” refers to the District Court which is basically synonymous with the district judge.

By the way, another (and more likely) possibility is that the decision issued by Judge Johnson was non-final, in which case he would have authority to modify or vacate it without using Rule 60.

For example, suppose the plaintiffs had sued to have the camp declared unconstitutional and also for money damages. In that case, it is possible that the Court could declare the camp unconstitutional and leave the issue of damages unresolved. In that case, the order would be non-final.

But the basic answer to your question is that yes, a federal district court can usually (with certain exceptions) vacate its earlier orders and will generally do so if all of the parties consent.