Quacy Tom Wright v. United States of America

Summary

The United States District Court for the Middle District of Alabama denied Quacy Tom Wright’s petition seeking information about court registry funds and his Rule 60(d)(3) motion alleging fraud on the court. The court held that the Freedom of Information Act does not apply to the federal judiciary, found that no relevant funds were held in the court registry, and concluded that Wright’s challenges to his criminal conviction were improper Rule 60 motions and could not be brought in that court.

Holdings

1. The federal judiciary is not an agency subject to the Freedom of Information Act because the statute expressly excludes the courts of the United States from the definition of agency.
2. Wright was not entitled to an accounting because the Middle District of Alabama held no monetary funds in its registry relating to his civil or criminal proceedings, and he identified no sound authority requiring that court to account for funds allegedly held by other courts.
3. Rule 60(d)(3) does not provide relief from a judgment in a criminal case.
4. A motion challenging the merits of a prior federal judgment or seeking to add a new ground for relief is properly treated as a habeas petition under 28 U.S.C. § 2255 rather than a Rule 60(d)(3) motion.
5. A § 2255 motion must be filed in the court that imposed the sentence; Wright therefore could not bring his criminal-conviction challenges through this Rule 60(d)(3) motion in the Middle District of Alabama.

Questions Presented

1. Whether Wright was entitled to an accounting of court registry funds under the Freedom of Information Act, federal statutes governing deposits into court, or other cited authorities.
2. Whether the federal judiciary is subject to the Freedom of Information Act.
3. Whether Wright could use Federal Rule of Civil Procedure 60(d)(3) to challenge his criminal conviction based on alleged fraud on the court.
4. Whether Wright's merits-based and ineffective-assistance claims had to be treated as a successive 28 U.S.C. § 2255 petition and, if so, whether they could be brought in the Middle District of Alabama rather than the court that imposed sentence.

Disposition

other