## Facts

- Spouses divorced after a long marriage; the husband founded and owned a computer software company (KSC).
- The divorce trial focused on valuing the husband’s interest in KSC, with both parties presenting expert valuation evidence, including financial projections.
- The Probate and Family Court valued the husband’s interest at $4,912,717, awarded him all KSC shares, and ordered him to pay the wife 30% of that value ($1,473,815) in annual installments over five years.
- The divorce judgment entered in 1996 and later became final.
- In 1999, KSC was acquired in a transaction valuing the company far higher than the divorce-era valuation.
- The wife filed a new action in 1999 seeking to set aside or reopen the property division, alleging the husband had misrepresented or failed to disclose significant information about KSC’s financial condition and prospects, rendering the judgment “manifestly unconscionable.”
- She sought relief both through an independent equity action and under Massachusetts Rule of Civil Procedure 60(b)(6).
- The husband obtained summary judgment dismissing the complaint; the wife appealed.

## Issues

1. Whether post-judgment relief was warranted because enforcing the divorce property division would be “manifestly unconscionable” under an independent equity action or Rule 60(b).
2. Whether alleged misrepresentations or omissions about KSC’s finances and prospects constituted “fraud on the court” permitting relief outside the one-year limit applicable to Rule 60(b)(3).
3. Whether claims fitting Rule 60(b)(2) (newly discovered evidence) or Rule 60(b)(3) (fraud/misrepresentation) could be pursued under Rule 60(b)(6) to avoid the one-year time bar.

## Decision

- The Supreme Judicial Court affirmed summary judgment for the husband and dismissal of the wife’s complaint.
- The court held the wife did not show “compelling and exceptional circumstances” or that enforcement of the 1996 judgment would be “manifestly unconscionable.”
- The court held that party misrepresentations or omissions about matters litigated in the case, without more, did not amount to “fraud on the court.”
- The court held Rule 60(b)(6) was unavailable because the wife’s allegations fell within Rule 60(b)(2) and (3), which are subject to a one-year filing limit.

## Legal Principles

- Post-judgment reopening of a divorce property division requires a showing that enforcement would be “manifestly unconscionable” or that other compelling, exceptional circumstances justify equitable relief.
- “Fraud on the court” is limited to extraordinary conduct that corrupts the judicial process itself; ordinary misrepresentations, nondisclosure, or omissions by a party concerning matters in dispute are addressed under Rule 60(b)(3), not the fraud-on-the-court doctrine.
- Rule 60(b)(6) cannot be used to recharacterize claims that fall within Rule 60(b)(2) or (3) in order to evade the one-year time limitation applicable to those subsections.
- Dramatic post-divorce appreciation of an asset, standing alone, generally reflects changed economic circumstances rather than a basis to set aside a final property division.

## Conclusion

The court enforced the final divorce judgment despite the later surge in the company’s value, ruling that the wife’s allegations amounted to time-barred claims of newly discovered evidence or fraud/misrepresentation and did not meet the stricter standards for “fraud on the court” or Rule 60(b)(6) relief.


Sahin v. Sahin, 758 N.E.2d 132 (Mass. 2001)