Andre Paige v. United States, 684 F. App'x 902

Andre Paige, a federal prisoner, filed a pro se motion styled as a "Motion to Re-open, Motion for Appointment of Counsel, Motion for Evidentiary Hearing," which the district court treated as a § 2255 motion (or alternatively a Rule 60(b) motion).
Paige had previously filed and been denied at least one § 2255 motion, making this a potentially successive § 2255 filing.
Paige did not obtain authorization from the court of appeals before filing the successive § 2255 motion in district court.
The district court denied Paige’s motion on the merits rather than dismissing it for lack of jurisdiction for being an unauthorized successive petition.
The government raised the jurisdictional defect on appeal, arguing the district court lacked authority to consider a successive § 2255 without appellate permission.
The Eleventh Circuit reviewed jurisdiction de novo, concluded the district court lacked subject-matter jurisdiction, vacated the denial, and remanded with instructions to dismiss for lack of jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court had jurisdiction to hear Paige’s motion	Paige treated his filings as requests for reopening, counsel, and evidentiary hearing (not as a successive § 2255)	The government argued the filing was a successive § 2255 and required court-of-appeals authorization	The motion was a successive § 2255/Rule 60(b) and the district court lacked jurisdiction without appellate permission
Whether relabeling a successive § 2255 avoids gatekeeping	Paige implicitly contended relabeling could allow district review	Government relied on precedent that label cannot evade § 2244(b) gatekeeping	Court held relabeling does not avoid the requirement to obtain authorization
Proper remedy when a district court rules on the merits of an unauthorized successive motion	Paige sought substantive relief and the district court adjudicated the motion	Government argued the court should have dismissed for lack of jurisdiction, not rule on merits	Court vacated the merits ruling and instructed district court to dismiss for lack of jurisdiction
Standard of review for jurisdictional question	N/A (jurisdictional matter)	N/A	Court reviewed jurisdiction de novo

Boyd v. Homes of Legend, Inc., 188 F.3d 1294 (11th Cir. 1999) (appellate review to correct lower court jurisdictional errors)
In re Blackshire, 98 F.3d 1293 (11th Cir. 1996) (authorization required before filing successive § 2255)
Farris v. United States, 333 F.3d 1211 (11th Cir. 2003) (district court lacks jurisdiction over unauthorized successive § 2255)
Williams v. Chatman, 510 F.3d 1290 (11th Cir. 2007) (vacating merits disposition and instructing dismissal for lack of jurisdiction)
Gilbert v. United States, 640 F.3d 1293 (11th Cir. 2011) (a prisoner cannot evade the gatekeeping rules by relabeling claims)
Hubbard v. Campbell, 379 F.3d 1245 (11th Cir. 2004) (affirming lack of jurisdiction to consider successive § 2255)