Randy A. Rice v. Warden Brian Eller

Summary

The United States District Court for the Western District of Tennessee denied Randy A. Rice’s motion for relief from judgment under Federal Rule of Civil Procedure 60(b). The court held that the motion was untimely under Rule 60(c)(1) and that the submitted affidavit did not establish exceptional circumstances or actual innocence warranting relief under Rule 60(b)(6). The court also noted that the motion attacked the merits of a prior habeas determination and therefore constituted a successive habeas petition requiring appellate authorization.

Holdings

1. A motion seeking relief under Rule 60(b)(1), (2), or (3) must be filed no more than one year after entry of the challenged judgment. Rice's motion, filed more than three years after the March 31, 2022 judgment, was untimely.
2. Rice did not file his Rule 60(b)(6) motion within a reasonable time.
3. The Rodgers affidavit did not establish exceptional or extraordinary circumstances warranting relief under Rule 60(b)(6), and it did not demonstrate Rice's actual innocence.
4. A Rule 60(b) motion that attacks the federal court's prior resolution of a habeas claim is properly treated as a second or successive habeas petition requiring authorization from the court of appeals.

Questions Presented

1. Whether Rice's Rule 60(b)(1) or Rule 60(b)(3) motion was timely when filed more than three years after entry of the judgment.
2. Whether Rice could obtain relief under Rule 60(b)(2) based on newly discovered evidence.
3. Whether the Rodgers affidavit established exceptional or extraordinary circumstances, or actual innocence, warranting relief under Rule 60(b)(6).
4. Whether the motion's attack on the prior merits resolution of the Brady claim made it a second or successive habeas petition requiring appellate authorization.

Disposition

other