The Fifth Circuit Court of Appeals has upheld a lower court's dismissal of a lawsuit filed by Deliris Montanez Berrios, a candidate in the 2024 elections. The court ruled against her attempts to reopen the case and denied her request for an injunction to preserve election-related records. This decision affects Berrios and her claims against Texas election officials, highlighting the challenges faced by individuals navigating the legal system without legal representation.

The case, Montanez Berrios v. Samaniego, was filed in the context of a write-in campaign for Texas’s Sixteenth Congressional District. Berrios, appearing pro se, meaning she represented herself, alleged several violations related to the election process. The court's ruling emphasizes the importance of timely legal actions and adherence to procedural rules.

Background

Deliris Montanez Berrios ran an unsuccessful write-in campaign for a congressional seat in Texas during the 2024 elections. Following her defeat, she filed a lawsuit against El Paso County Judge Ricardo Samaniego and the Texas Secretary of State, Robert S. Howden. Berrios claimed that there were several election-related violations that impacted her campaign.

The case was initially heard in the Western District of Texas, where the district court granted motions to dismiss from the defendants. The court also denied Berrios' motions to join additional defendants, add a new cause of action, and lift a stay on discovery. This stay was imposed while the motions to dismiss were being resolved.

After the district court's dismissal of her claims on January 30, 2026, Berrios filed a motion under Federal Rule of Civil Procedure 60(b) on March 16, 2026, seeking to reopen her case. The following day, she also requested a preliminary injunction. Both motions were denied by the district court on March 18, 2026. Berrios subsequently filed a second Rule 60(b) motion on March 22, 2026, which was also denied. This led to her appeal to the Fifth Circuit.

The Ruling

The Fifth Circuit Court affirmed the district court's decision, stating that Berrios' second Rule 60(b) motion did not demonstrate an abuse of discretion by the lower court. The judges noted that Berrios' arguments primarily focused on the underlying dismissal rather than the specific reasons for her Rule 60(b) motion.

The court ruled, "Neither Plaintiff’s second motion nor her briefing on appeal show that the district court abused its discretion."

The court emphasized that a Rule 60(b) motion cannot be used as a way to circumvent the time limits for filing an appeal. The judges pointed out that Berrios filed her motions after the deadline for appealing the district court's final judgment. They concluded that her claims of obstruction of justice and violations of civil rights were not sufficient to warrant reopening the case.

Additionally, the court addressed Berrios' motion for an injunction pending appeal, which sought to preserve election-related records. The judges found that she did not meet the requirements for such relief, stating that she failed to show a strong likelihood of success on the merits or that irreparable injury would occur without the injunction.

The court stated, "Plaintiff establishes none of the injunction factors."

Impact

This ruling carries significant implications for Berrios and others who may consider legal action related to election processes. The court's decision reinforces the necessity for timely filings and adherence to procedural rules in the legal system. It also highlights the challenges faced by pro se litigants, who may struggle to effectively present their cases without legal representation.

Furthermore, the ruling sets a precedent regarding the use of Rule 60(b) motions, clarifying that such motions cannot be used to extend the time for filing appeals if they are submitted after the designated deadlines. This decision may deter similar future attempts by other candidates or individuals seeking to challenge election-related outcomes.

What's Next

Details were not available in the court filing regarding whether Berrios plans to appeal this decision further. However, the ruling from the Fifth Circuit is generally considered final unless a party can present new evidence or arguments that warrant further review.