United States v. Omari Patton, 670 F. App'x 40

In 2004 Omari Patton was convicted by a federal jury of multiple drug offenses and sentenced to 360 months’ imprisonment; the conviction was affirmed on direct appeal.
Patton filed multiple postconviction motions (§ 2255, Rule 36, § 3582(c)(2), and requests to file successive collateral attacks); all were denied except a § 3582(c)(2) motion in July 2015.
The District Court reduced Patton’s sentence to 294 months pursuant to U.S.S.G. Amendment 782 and entered an amended judgment.
In June 2016 Patton wrote the District Court complaining that the written statement of reasons accompanying the amended judgment was incomplete (page three left blank) and requested either a complete statement or that the sentence be vacated so the court could give concrete reasons.
The District Court denied the request, explaining the reasons were provided on page one and no further space was needed; Patton timely appealed.
The Third Circuit concluded no certificate of appealability (COA) was required and summarily affirmed the District Court’s June 14, 2016 order, finding the written statement of reasons sufficient and the appeal raised no substantial question.

Issue	Patton's Argument	Government's Argument	Held
Whether a COA was required to appeal the District Court’s denial of Patton’s request for a more complete statement of reasons	Patton alternatively asked the court to "vacate" the sentence and supply a complete statement of reasons, implying collateral review need	The letter did not seek release and did not constitute a § 2255 (or related) motion; it only sought a written explanation	No COA required because Patton did not claim a right to be released and the filing did not amount to a § 2255 collateral attack
Whether the District Court’s written statement of reasons accompanying the amended sentence was adequate	The written form left page three blank and Patton argued the statement was incomplete and insufficiently concrete	The District Court had provided reasons (on page one); the blank page was mere formatting and not indicative of insufficiency	Affirmed: the statement of reasons was sufficient; appeal presented no substantial question and was summarily affirmed

United States v. Patton, [citation="292 Fed. App'x 159"] (3d Cir. 2008) (affirming Patton’s original conviction and sentence)
United States v. Patton, [citation="644 Fed. App'x 125"] (3d Cir. 2016) (upholding sufficiency of the District Court’s form and rationale for the amended sentence)
Antonioli v. Lehigh Coal & Navigation Co., 451 F.2d 1171 (3d Cir. 1971) (second appeal cannot relitigate issues already decided by the same court)