Harry Brantley v. Chad Dotson

Summary

The United States District Court for the Eastern District of Virginia denied Harry Brantley's motion to alter judgment and dismissed without prejudice his Rule 60(b)(4) motion, construing it as a second or successive habeas petition under 28 U.S.C. § 2244(b). The court held that it lacked jurisdiction because Brantley had not obtained authorization from the Fourth Circuit to file a successive petition. The court also explained that Rule 60(b) could not be used to challenge a state-court judgment and directed the Clerk to close the action.

Holdings

1. A filing styled as a Rule 60(b) motion is treated as a second or successive habeas petition when it attacks the underlying state-court conviction or judgment previously challenged in federal habeas proceedings, rather than identifying a defect in the integrity of the prior federal habeas proceeding.
2. A federal district court lacks jurisdiction to consider a second or successive habeas petition absent an order from the appropriate court of appeals authorizing its filing.
3. Federal Rule of Civil Procedure 60(b) does not provide a mechanism for a federal district court to relieve a party from or invalidate a judgment entered by a state court.

Questions Presented

1. Whether Brantley's Rule 60(b)(4) motion was substantively a second or successive habeas petition subject to 28 U.S.C. § 2244(b).
2. Whether the district court had jurisdiction to consider the successive petition without prior authorization from the Fourth Circuit.
3. Whether Federal Rule of Civil Procedure 60(b) authorized the federal district court to invalidate or otherwise challenge the state-court judgment.
4. Whether the petition should be dismissed without prejudice and the motion to alter judgment denied.

Disposition

dismissed