Charles Wright v. Warden, Riverbend Maximum Security Institution
793 F.3d 670
6th Cir.2015Background
- Charles Walton Wright, convicted in Tennessee (1985) of two first-degree murders; sentenced to life for one count and death for the other; convictions and sentences affirmed on direct appeal.
- Wright pursued multiple state post-conviction petitions (three), federal habeas relief (filed 1999, denied; affirmed by Sixth Circuit in Wright v. Bell), and has repeatedly litigated his claims up to the U.S. Supreme Court (denials of review).
- In 2013 Wright filed a Federal Rule of Civil Procedure 60(b)(6) motion seeking to reopen his federal habeas judgment, relying on the Supreme Court’s Martinez v. Ryan and Trevino v. Thaler developments to excuse procedural default of an ineffective-assistance-of-trial-counsel mitigation claim.
- The district court denied his renewed Rule 60(b)(6) motion; Wright appealed and was granted a COA on the Rule 60(b)(6) issue.
- The Sixth Circuit affirmed, holding that Martinez/Trevino did not constitute an extraordinary circumstance justifying Rule 60(b)(6) relief and that equitable factors (finality, extensive prior litigation, weak underlying claim) weighed against reopening.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Martinez/Trevino constitute "extraordinary circumstances" warranting Rule 60(b)(6) relief to reopen a final habeas judgment | Martinez and Trevino change procedural-default law to permit federal review of defaulted ineffective-assistance claims when state collateral-review counsel was ineffective; this should justify reopening | Martinez/Trevino are an adjustment of equitable doctrine, not a constitutional change; changes in law generally are not extraordinary for Rule 60(b)(6); finality and comity weigh against reopening | Denied — Martinez/Trevino do not amount to extraordinary circumstances for Rule 60(b)(6) relief |
| Whether equitable factors (diligence, finality, state and federal interests) support reopening | Wright acted diligently in pursuing Martinez-based relief and equitable considerations (risk to life) favor reconsideration | Long delay, extensive prior litigation, strong interests in finality and comity, and weak underlying claim counsel against reopening | Denied — equity weighs against relief despite diligence; finality and comity are controlling |
| Whether the underlying ineffective-assistance mitigation claim warrants relief on the merits if reopened | If procedural default excused, the mitigation claim would merit review and potentially relief | Even if Martinez/Trevino applied, the claim lacks merit based on the record; prior Sixth Circuit alternative merits ruling forecloses relief | Denied — underlying claim weak; prior alternative merits ruling (Wright v. Bell) provides independent reason to deny reopening |
Key Cases Cited
- Martinez v. Ryan, 132 S. Ct. 1309 (2012) (establishes limited equitable exception to procedural-default rules for ineffective-assistance-at-state-post-conviction-review claims)
- Trevino v. Thaler, 133 S. Ct. 1911 (2013) (applies Martinez framework in certain state-court systems where state post-conviction counsel was ineffective)
- McGuire v. Warden, 738 F.3d 741 (6th Cir. 2013) (Martinez/Trevino are not the kind of change in law that by themselves create extraordinary circumstances for Rule 60(b)(6))
- Gonzalez v. Crosby, 545 U.S. 524 (2005) (Rule 60(b) relief requires extraordinary circumstances; not every change in habeas interpretation warrants reopening)
- Wright v. Bell, 619 F.3d 586 (6th Cir. 2010) (prior Sixth Circuit decision rejecting Wright's habeas claims on both procedural-default and alternative merits grounds)
- Henness v. Bagley, 766 F.3d 550 (6th Cir. 2014) (reiterating that Martinez/Trevino generally do not justify Rule 60(b)(6) relief)