Paul Satterfield v. District Attorney Philadelphia, 669 F. App'x 616

Paul Satterfield, serving a life sentence from a 1985 state murder conviction, filed a federal habeas petition in January 2002.
The District Court initially granted relief, but this Court reversed and instructed dismissal of the petition as time-barred; the District Court entered dismissal on April 19, 2006.
In 2013 Satterfield sought Rule 60(b) relief invoking McQuiggin v. Perkins; the District Court denied relief and Satterfield obtained a COA for that appeal (pending as CA No. 15-2190).
In 2016 Satterfield moved under Fed. R. App. P. 10(e) to correct the appellate record, arguing the court-supplied habeas form erroneously identified the county District Attorney (DA) as a respondent and that the DA’s appearance should be excised.
The District Court denied the Rule 10(e) motion, noting it had previously rejected Satterfield’s effort to erase the DA from the case history and that the DA had been lawfully added and had standing to appeal.
The Third Circuit summarily affirmed, holding Satterfield raised and lost the same challenge earlier and that no record omission caused by "error or accident" warranted Rule 10(e) relief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court record should be corrected under Fed. R. App. P. 10(e) to remove the DA as a party-respondent	The DA was improperly identified by a court-supplied habeas form; only the jailor and state AG are proper respondents under Habeas Rule 2(a), so the DA’s appearance should be excised	The DA was lawfully added by court order, had standing, and the court previously rejected Satterfield’s challenge	Affirmed: no correction under Rule 10(e); issue had been raised and rejected and no material omission from error or accident was shown
Whether the appeal record contains the kind of material omission or dispute about what occurred that Rule 10(e) authorizes correcting	The docket omitted service date and mischaracterized parties due to form error	The record accurately reflects the court’s actions; prior rulings established the DA’s participation	Affirmed: no "error or accident" or disputed factual omission that would permit augmentation/correction

McQuiggin v. Perkins, 133 S. Ct. 1924 (2013) (actual-innocence gateway to overcome AEDPA time bar)
Satterfield v. Johnson, 434 F.3d 185 (3d Cir. 2006) (appeal reversing grant of habeas relief as time-barred)
United States v. Hernandez, 227 F.3d 686 (6th Cir. 2000) (district-court factual determinations about what occurred are conclusive absent intentional falsity or plain unreasonableness)
United States v. Graham, 711 F.3d 445 (4th Cir. 2013) (same principle regarding district-court settlement of record disputes)
Fassett v. Delta Kappa Epsilon, 807 F.2d 1150 (3d Cir. 1986) (Fed. R. App. P. 10(e) governs augmentation when record omits material matter by error or accident)
Tourscher v. McCullough, 184 F.3d 236 (3d Cir. 1999) (appellate court may affirm on any ground supported by the record)
Marron v. Atlantic Refining Co., 176 F.2d 313 (3d Cir. 1949) (historical discussion of record-correction principles)