Farris v. Martin, 21-6077

Tyrone Leslie Farris, an Oklahoma state prisoner serving a 99‑year sentence, filed a § 2241 petition claiming denial of sentencing credits by the Oklahoma DOC.
The Western District of Oklahoma dismissed the § 2241 petition as untimely; Farris’s timely appeal to this court was dismissed as untimely.
Farris then filed a Rule 60(b)(6) “Motion for Reconsideration” alleging judicial bias (seeking disqualification) and rearguing the merits of his § 2241 claim.
The district court denied the Rule 60(b)(6) motion and declined to grant a certificate of appealability (COA).
Farris sought a COA from the Tenth Circuit to appeal the denial of his Rule 60(b) motion; the Tenth Circuit evaluated whether a reasonable jurist could conclude the district court abused its discretion in refusing to reopen the judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether COA required to appeal denial of Rule 60(b) in § 2241 habeas	COA should be granted to review denial of Rule 60(b) motion	COA is required under § 2253(c)(1)(A) for habeas orders tied to state detention	COA required; Farris applied but standard not met
Whether alleged judicial bias/disqualification warranted reopening	Judges were biased and should have been disqualified	Bias allegations rested only on adverse rulings; adverse rulings alone do not require recusal	Denied—adverse rulings insufficient to show disqualifying bias
Whether re‑argument of § 2241 merits in Rule 60(b) warranted relief	Motion reargued merits of § 2241 claim and sought relief from final judgment	District court properly refused to rehash issues previously decided; no duty to relitigate same claims	Denied—district court did not abuse discretion in refusing to reopen
Whether Rule 60(b) relief here required prior appellate authorization as second/successive	Relief could be treated as second/successive requiring appellate permission	Prior-authorization rule for § 2254/2255 does not apply to § 2241; district court may address § 2241 Rule 60(b) matters	Not applicable here; district court had authority to consider motion without prior appellate permission

Montez v. McKinna, 208 F.3d 862 (10th Cir. 2000) (COA requirement applies when state prisoner habeas petition relates to state‑court detention orders, including § 2241)
Buck v. Davis, 137 S. Ct. 759 (U.S. 2017) (COA standard for reviewing denial of Rule 60(b) relief: whether a reasonable jurist could conclude the district court abused its discretion)
Gonzalez v. Crosby, 545 U.S. 524 (U.S. 2005) (distinguishes “true” Rule 60(b) motions from second‑or‑successive habeas petitions)
United States v. Wells, 873 F.3d 1241 (10th Cir. 2017) (adverse rulings alone do not justify judicial disqualification)
Allender v. Raytheon Aircraft Co., 439 F.3d 1236 (10th Cir. 2006) (district court not required to repeat rulings or relitigate already‑decided issues)
Stanko v. Davis, 617 F.3d 1262 (10th Cir. 2010) (prior‑authorization requirement for second‑or‑successive petitions does not apply to § 2241 proceedings)