Paul Satterfield v. District Attorney Philadelphia
872 F.3d 152
| 3rd Cir. | 2017Background
- Paul Satterfield, a Black man, was convicted of first-degree murder in 1985 based largely on a witness (Wayne Edwards) who testified Satterfield confessed; two eyewitnesses (Eric and Grady Freeman) originally described a light-skinned/white shooter and were not called at trial by defense counsel.
- Postconviction proceedings raised an ineffective-assistance-of-counsel (IAC) claim for failing to present the Freeman brothers; a district court granted relief on that claim but this was reversed as the federal habeas petition was deemed time-barred under AEDPA.
- The Supreme Court’s 2013 decision in McQuiggin v. Perkins held that a credible showing of actual innocence can overcome AEDPA’s one-year statute of limitations (the "fundamental miscarriage of justice" exception).
- In 2014 Satterfield moved under Fed. R. Civ. P. 60(b)(6) to reopen the final judgment dismissing his habeas petition, arguing McQuiggin constituted an extraordinary intervening change in law justifying relief.
- The district court denied the 60(b)(6) motion; the Third Circuit vacated and remanded, holding the district court failed to undertake the required equitable, case-specific analysis under Cox v. Horn and explaining McQuiggin’s nature must be weighed in that analysis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether McQuiggin’s change in law can be an "extraordinary circumstance" for Rule 60(b)(6) relief | McQuiggin is an intervening, substantive change (allows actual-innocence gateway to overcome AEDPA timeliness) that justifies reopening final judgment | A change in precedent rarely qualifies; Gonzalez forecloses using intervening habeas-law changes to reopen final judgments | Vacated and remanded: change in law can support 60(b)(6) when paired with equitable factors; district court must analyze full equitable circumstances per Cox |
| What standard governs Rule 60(b)(6) motions based on intervening decisional law | Courts should weigh case-specific equitable factors and the nature of the change in law | Emphasized finality and that changes in law alone are usually insufficient | Apply Cox multifactor equitable analysis; remand for articulated balancing |
| Role of actual-innocence showing under McQuiggin in 60(b)(6) analysis | If Satterfield could make the Schlup/McQuiggin actual-innocence showing, McQuiggin’s change weighs heavily toward relief | State stresses finality, comity, and prior circuit practice that did not recognize an actual-innocence timeliness exception | Court held that a credible actual-innocence showing is a threshold and pivotal factor; if met, McQuiggin likely renders the change extraordinary unless other equities strongly oppose |
| Relevance of previously found meritorious IAC claim to 60(b)(6) relief | The District Court’s earlier grant on IAC increases equities favoring relief (serious constitutional error) | State argues passage of time and comity reduce weight of reopening case | Court: the gravity of underlying constitutional error (Strickland violation) is an important equitable factor to consider on remand |
Key Cases Cited
- McQuiggin v. Perkins, 133 S. Ct. 1924 (2013) (actual-innocence gateway can overcome AEDPA statute of limitations)
- Gonzalez v. Crosby, 545 U.S. 524 (2005) (limits on reopening habeas judgments by Rule 60(b); intervening statutory interpretations do not automatically justify relief)
- Cox v. Horn, 757 F.3d 113 (3d Cir. 2014) (intervening changes in law may justify Rule 60(b)(6) relief in appropriate, equity-driven, case-specific circumstances)
- Schlup v. Delo, 513 U.S. 298 (1995) (standard for credible showing of actual innocence)
- Strickland v. Washington, 466 U.S. 668 (1984) (ineffective-assistance-of-counsel standard)
- Murray v. Carrier, 477 U.S. 478 (1986) (articulating miscarriage-of-justice/equitable principles that can overcome procedural bars)
- Buck v. Davis, 137 S. Ct. 759 (2017) (seriousness of underlying constitutional error is a factor in Rule 60(b)(6) equitable analysis)
- House v. Bell, 547 U.S. 518 (2006) (actual-innocence considerations can outweigh finality and comity)