Tenth District: no jurisdiction over appeal from denial of motion for reconsideration

The reason being, of course, that motions for reconsideration of a final judgment simply don't exist under the Civil Rules. Denials of motions for reconsideration therefore can't be final orders, and the court of appeals has no jurisdiction over appeals from non-final orders.

But there is a lot more going on in this case.

Rule 60(B)(4) - when does it apply?

Rule 60(B) provides for relief from a final judgment on certain specified conditions, including mistake or excusable neglect, newly discovered evidence, and fraud or misrepresentation. Subdivision (4) provides for relief if "the judgment has been satisfied, released or discharged," and honestly, it's never been clear to me when or why that might warrant the vacature of a judgment. I understand why a judgment might be noted as "paid" or "satisfied," but why should that be grounds for relief from the judgment? The Second District has an answer, though not necessarily an entirely satisfying one, in Kossoudji v. Stamps.