Hunt v. Eppinger, 1:20-cv-02666

Rashan Hunt filed a federal habeas corpus petition challenging his state court convictions from Cuyahoga County, Ohio.
The magistrate judge recommended that the petition be denied in part and dismissed in part; the district court adopted this recommendation and denied Hunt’s motion to stay.
Hunt, proceeding pro se, then filed a Rule 59(e) motion to alter or amend the judgment, raising three arguments regarding procedural errors and the merits of his objections.
Hunt argued for a stay pending an appeal, claimed denial of an opportunity to file timely objections due to counsel issues, and asserted he had meritorious objections to the magistrate’s report.
The respondent opposed, stating any appeal would be non-cognizable on federal habeas, the procedural timeline was sufficient, and failure to object timely constitutes forfeiture.
The Court denied Hunt's motion, finding no basis under Rule 59(e)’s grounds (legal error, new evidence, change in law, manifest injustice).

Issue	Hunt’s Argument	Eppinger’s Argument	Held
Denial of motion to stay pending appeal	Appeal was not time-barred; stay should have been granted	Appeal would be on a state law issue; not cognizable for federal habeas	Denied, non-cognizable as federal claim
Opportunity to file objections to R&R	Counsel did not give him R&R timely; deprived of chance to object	Record refutes; extensions provided, could object pro se after withdrawal	Denied, had adequate opportunity
Meritorious objections to R&R	Court failed to recognize validity of his objections	Existing law and facts do not support changing the judgment	Denied, objections insufficient
Standard for altering/amending judgment (Rule 59)	Claims error of law and need to prevent injustice	No new law, evidence, or injustice; legal grounds not met	No grounds to alter/amend established

Michigan Flyer LLC v. Wayne Cty. Airport Auth., 860 F.3d 425 (6th Cir. 2017) (sets out Rule 59(e) standard for altering or amending a judgment)
Morse v. McWhorter, 290 F.3d 795 (6th Cir. 2002) (affirms district court's broad discretion on Rule 59(e) motions)
Haines v. Kerner, 404 U.S. 519 (1972) (establishes that pro se pleadings receive less stringent review)
McDonald v. Hall, 610 F.2d 16 (1st Cir. 1979) (court not required to create claims for pro se litigants)
Clark v. Nat’l Travelers Life Ins. Co., 518 F.2d 1167 (6th Cir. 1975) (reinforces limits on court’s obligation with pro se plaintiffs)
Beaudett v. City of Hampton, 775 F.2d 1274 (4th Cir. 1985) (explains practical limits on judicial assistance to pro se parties)