Summary
The United States District Court for the Eastern District of Wisconsin denied Anthony Hill’s motion under Federal Rule of Civil Procedure 59(e) to reconsider the dismissal of his federal habeas petition. The court held that Hill had not shown a manifest error of law or fact, newly discovered evidence, or grounds to revisit the procedural default of his Confrontation Clause claim.
Topics
Practice areas
Questions Presented
- Whether Hill satisfied the requirements for relief under Federal Rule of Civil Procedure 59(e) by showing a manifest error of law or fact or newly discovered evidence.
- Whether the court's treatment of Ground Eight as procedurally defaulted constituted a manifest error requiring reconsideration.
Holdings
- A Rule 59(e) motion may succeed only when the movant clearly establishes a manifest error of law or fact or newly discovered evidence that precluded entry of judgment.
- The court did not commit a manifest error of law or fact in denying relief on Ground Eight, and Hill's assertion that he could file a Knight petition did not justify reconsideration.
Key quotations
“The motion “will be successful only where the movant clearly establishes: ‘(1) that the court committed a manifest error of law or fact, or (2) that newly discovered evidence precluded entry of judgment.’”” (Legal Standard)
““Reconsideration is not an appropriate forum for rehashing previously rejected arguments or arguing matters that could have been heard during the pendency of the previous motion.”” (Legal Standard)
“Because the petitioner has not met his burden to show that the court committed a manifest error of law or fact, and because he has not identified any newly discovered evidence, the court will deny his motion to reconsider.” (Conclusion)
Factual background
Hill was convicted of armed robbery in Rock County Circuit Court in 2014 and later filed a federal habeas petition identifying eight grounds for relief. Ground Eight asserted a Confrontation Clause violation, but Hill had not fairly presented that claim to the Wisconsin Court of Appeals and had not established cause and prejudice or a miscarriage of justice to excuse the procedural default. In seeking reconsideration, Hill argued that he could still return to state court through a Knight petition.
Procedural history
Hill filed a federal habeas petition challenging his 2014 Wisconsin armed-robbery conviction. The court denied his motion for stay and abeyance, later denied the habeas petition, rejected several grounds, found Ground Eight procedurally defaulted, dismissed the case, and declined to issue a certificate of appealability. Hill then moved for reconsideration, asserting that he could still pursue a state-court Knight petition to exhaust Ground Eight.