context: In the rare cases where we have found an abuse of discretion in a district court's refusal to grant an extension of time, our analysis has been highly fact-specific. We have granted relief when the appealing litigant was reasonably surprised by the deadline or the action of the court, or the events leading to the contested decision were unfair.
citation_a.signal: see also
citation_a.identifier: 360 F.3d 286, 290-91
citation_a.parenthetical: holding that it was "simply unfair-- and an abuse of discretion" for district court to deny non-moving party's motion for reconsideration of summary judgment after the court had "switched the basic issue without giving the parties adequate warning"
citation_a.sentence: See United States v. Fraya, 145 F.3d 1, 4 (1st Cir.1998) (reversing grant of summary judgment where non-moving party’s delay was attributable to “an ambiguity in the Local Rules” and a snafu in the district court clerk’s office); United States v. Roberts, 978 F.2d 17, 20-21 (1st Cir.1992) (overturning grant of motion to suppress when government’s failure to respond was due to “interlocking rules ... freighted with ambiguity”); see also Douglas v. York County, 360 F.3d 286, 290-91 (1st Cir.2004) (holding that it was “simply unfair— and an abuse of discretion” for district court to deny non-moving party’s motion for reconsideration of summary judgment after the court had “switched the basic issue without giving the parties adequate warning”); Resolution Trust Corp. v. North Bridge Assoc., Inc., 22 F.3d 1198, 1200, 1209 (1st Cir.1994) (reversing grant of summary judgment when non-moving party was “laid low” by the moving party’s “rabbit punch,” and “the district court should not have countenanced, much less rewarded, such dubious conduct”); Mendez, 900 F.2d at 7 (declining to overrule district court’s refusal to extend time in part because “the lawyer had no valid basis to claim he was surprised” by the filing deadline).
citation_b.signal: see
citation_b.identifier: 978 F.2d 17, 20-21
citation_b.parenthetical: overturning grant of motion to suppress when government's failure to respond was due to "interlocking rules ... freighted with ambiguity"
citation_b.sentence: See United States v. Fraya, 145 F.3d 1, 4 (1st Cir.1998) (reversing grant of summary judgment where non-moving party’s delay was attributable to “an ambiguity in the Local Rules” and a snafu in the district court clerk’s office); United States v. Roberts, 978 F.2d 17, 20-21 (1st Cir.1992) (overturning grant of motion to suppress when government’s failure to respond was due to “interlocking rules ... freighted with ambiguity”); see also Douglas v. York County, 360 F.3d 286, 290-91 (1st Cir.2004) (holding that it was “simply unfair— and an abuse of discretion” for district court to deny non-moving party’s motion for reconsideration of summary judgment after the court had “switched the basic issue without giving the parties adequate warning”); Resolution Trust Corp. v. North Bridge Assoc., Inc., 22 F.3d 1198, 1200, 1209 (1st Cir.1994) (reversing grant of summary judgment when non-moving party was “laid low” by the moving party’s “rabbit punch,” and “the district court should not have countenanced, much less rewarded, such dubious conduct”); Mendez, 900 F.2d at 7 (declining to overrule district court’s refusal to extend time in part because “the lawyer had no valid basis to claim he was surprised” by the filing deadline).