Kamdem-Ouaffo v. Balchem Corporation — 2d Cir. (Sep 23, 2026)
The Second Circuit hears two related appeals by Ricky Kamdem-Ouaffo against his former employer, Balchem Corporation. He sued after alleging workplace harassment and wrongful termination. His first suit was dismissed after he missed a court-ordered deposition; the second was dismissed as duplicative. Years later, he asked to reopen both judgments, but a March 2025 order refused permission. Representing himself, Kamdem-Ouaffo asks the appeals court to revisit that refusal. Rule 60(b)(4) concerns a judgment that is void; Rule 60(b)(6) permits relief for other extraordinary reasons. He says the magistrate judge exceeded his authority and that a rule about applying new decisions to pending appeals supports reopening one case. Two days after this hearing, the panel affirmed both denials, finding the requests too late and the proposed grounds insufficient.
Kamdem-Ouaffo v. Balchem Corporation (No. 25-1056, 25-1116) — U.S. Court of Appeals for the Second Circuit, argued September 23, 2026.
- 0:00Introduction
- 2:02Griffith and Harper
- 4:49Rule 72(a)