United States v. Charles Pyne
686 F. App'x 157
| 4th Cir. | 2017Background
- Charles Pyne appealed the district court’s denials of his motions to recuse the judge, to unseal transcripts, and to alter or amend (Rule 59(e)) prior orders related to his postconviction relief efforts.
- The district court had denied in part Pyne’s request for Rule 60(d)(3) relief and dismissed part of his 28 U.S.C. § 2255 claims as successive.
- Pyne sought a certificate of appealability (COA) challenge to the dismissal-as-successive ruling and appealed other denials (recusal, unsealing, and denial of Rule 60(d)(3) relief).
- The Fourth Circuit reviewed whether Pyne made the substantial showing required for a COA and separately reviewed the merits of the other denials for reversible error.
- The Fourth Circuit concluded Pyne failed to show a denial of a constitutional right warranting a COA and found no reversible error as to the motions to recuse, unseal, or to alter/amend regarding Rule 60(d)(3).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether COA should issue for dismissal of § 2255 claims as successive | Pyne argued the dismissal implicated constitutional rights and merits appellate review | Government argued Pyne failed to make the substantial showing required for a COA | COA denied; appeal dismissed in part because Pyne did not meet the Slack standard |
| Whether Rule 59(e) motion to alter/amend was properly denied | Pyne sought reconsideration of prior rulings and Rule 60(d)(3) relief | Government argued the motion re-litigated issues, lacked new law or evidence | Denial affirmed; motion was improper re-litigation, not based on intervening law or new evidence |
| Whether the district judge should have recused | Pyne alleged bias/favoritism making fair judgment impossible | Government maintained no factual basis for recusal and prior rulings don’t show bias | Denial of recusal affirmed; no factual basis or judicial conduct meeting Liteky/§455 standards |
| Whether transcripts should be unsealed to adjudicate Pyne’s motions | Pyne claimed unsealing was necessary to decide his Rule 59(e) motion | Government argued unsealing was unnecessary and record did not require it | Denial of unsealing affirmed; record showed unsealing was not necessary for adjudication |
Key Cases Cited
- Slack v. McDaniel, 529 U.S. 473 (2000) (standard for certificate of appealability; differing standards for merits vs. procedural denials)
- Miller-El v. Cockrell, 537 U.S. 322 (2003) (clarifies COA standard and review by reasonable jurists)
- Exxon Shipping Co. v. Baker, 554 U.S. 471 (2008) (motion to alter/amend may be inappropriate when re-litigating previously adjudicated matters)
- Liteky v. United States, 510 U.S. 540 (1994) (standards for judicial recusal based on bias or prejudice)
- Mayfield v. Nat’l Ass’n for Stock Car Auto Racing, Inc., 674 F.3d 369 (4th Cir. 2012) (standards for Rule 59(e) motions and reconsideration)
- United States v. Cherry, 330 F.3d 658 (4th Cir. 2003) (recusal standards under § 455)