Amin Rashid v. Warden Philadelphia FDC, 666 F. App'x 96

Amin A. Rashid was convicted in 2013 in the E.D. Pa. on multiple mail fraud and aggravated identity theft counts and sentenced to 240 months; this Court affirmed and the Supreme Court denied certiorari.
Rashid filed a 28 U.S.C. § 2241 petition in the E.D. Pa. (where he is confined) claiming actual innocence of a 1980 Oregon conviction (18 U.S.C. § 2314) that was used to enhance his 2013 sentence.
He also filed motions to disqualify the District Judge under 28 U.S.C. § 455(a) and sought vacatur of the 1980 conviction and the enhancement.
The District Court dismissed the § 2241 petition for lack of jurisdiction (Rashid was no longer "in custody" on the 1980 conviction) and held § 2255 provided an adequate remedy to challenge the 2013 enhancement.
Post-judgment, the District Court denied Rashid’s motions for reconsideration and to reopen for disqualification as meritless; the Government had sought an injunction against further filings as abusive, which the court denied as moot.
The Third Circuit summarily affirmed the denial of reconsideration and the denial of the motion to reopen/disqualify, finding no substantial question and noting the disqualification motion was frivolous.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the District Court had jurisdiction to entertain a § 2241 challenge to a 1980 conviction used to enhance a later sentence	Rashid: He is actually innocent of the 1980 conviction and seeks vacatur; § 2241 is available because the prior conviction improperly enhanced his current sentence	Gov't: Rashid is not "in custody" for the 1980 conviction; § 2255 is the proper, available remedy to challenge the 2013 enhancement	Court: Dismissed § 2241 for lack of jurisdiction; § 2255 is an adequate remedy
Whether the District Court erred in denying reconsideration of the dismissal	Rashid: Seeks reconsideration based on alleged errors in prior ruling	Gov't: No basis for reconsideration; original dismissal was correct	Court: Denial proper—no intervening law, new evidence, or clear error warranting reconsideration
Whether the District Judge should be disqualified under 28 U.S.C. § 455(a)	Rashid: Judge exhibited bias warranting recusal	Gov't: No extrajudicial source of bias; motions are abusive/vexatious	Court: Disqualification motion frivolous and properly denied
Whether the appeal presents any substantial question warranting full merits briefing	Rashid: Seeks review of the post-judgment denials and related orders	Gov't: No substantial question; summary affirmance appropriate	Court: Summarily affirmed under Third Cir. rules

Max’s Seafood Café v. Quinteros, 176 F.3d 669 (3d Cir. 1999) (standards for reconsideration motions)
United States v. Rashid, [citation="593 F. App'x 132"] (3d Cir. 2014) (prior opinion addressing bias claims and affirming convictions)