United States v. Reynolds
249 F. Supp. 3d 466
| D.D.C. | 2017Background
- Jason Todd Reynolds, a federal inmate convicted in 2011, filed a 28 U.S.C. § 2255 motion (ineffective assistance of counsel). The district court held an evidentiary hearing on Feb. 2–3, 2015 and denied relief on Feb. 19, 2015.
- BOP initially refused to let Reynolds travel to the hearing, citing a chickenpox outbreak and his lack of immunity; counsel moved to compel and later arranged for Reynolds to testify by video.
- Reynolds testified by video on Feb. 2; the video feed was disconnected after his testimony and he did not participate further. Counsel told the court they had discussed procedures and proceeded without Reynolds present for the remainder.
- Reynolds filed a Rule 60(b) / 60(d) petition (Nov. 2, 2016) alleging BOP fraud, deprivation of due process, constitutional violations by BOP case manager Charles Wilson, falsified prison records (affecting custody and programs), and a FOIA violation.
- The Government opposed; the court treated non-Rule 60 claims as a complaint and considered dismissal or summary judgment where appropriate. The court denied the Rule 60 petition and dismissed or declined the ancillary claims for the reasons below.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Rule 60(b)(3) — fraud/misrepresentation | BOP misrepresented medical test results to keep Reynolds from appearing, prejudicing his §2255 hearing | Motion under 60(b)(3) is time-barred because filed >1 year after judgment | Denied: 60(b)(3) relief precluded by Rule 60(c)(3)'s one-year limit |
| Rule 60(b)(4) — void judgment for due process violation | Deprivation of opportunity to be heard (couldn't participate after testimony) rendered judgment void | Reynolds appeared, had notice, testified by video; counsel consented to limited participation | Denied: no due process violation; counsel waived full participation, judgment not void |
| Rule 60(d)(3) — fraud on the court | BOP engaged in fraud on the court by fabricating test results and disconnecting video | Allegations do not show fraud on the court; evidence shows lack of immunity (transmission risk) justified travel restriction; no court officer participated in deception | Denied: does not meet the high standard for fraud on the court |
| Bivens and prison-records claims; FOIA | Wilson violated constitutional rights by disconnecting video; BOP falsified records affecting programs/time; DOJ failed FOIA duties | Counsel agreed to video-limited appearance; exhaustion required for prison-conditions claims; FOIA matter pending in other case | Bivens claims dismissed (no constitutional violation alleged); prison-records claim dismissed for failure to exhaust administrative remedies (or alternate summary judgment); FOIA claim dismissed without prejudice for lack of jurisdiction |
Key Cases Cited
- United Student Aid Funds, Inc. v. Espinosa, 559 U.S. 260 (procedural due process / Rule 60(b)(4) standard)
- Philip Morris USA Inc. v. United States, 840 F.3d 844 (D.C. Cir.) (scope of Rule 60(b)(4) and due process grounds)
- Bell Helicopter Textron, Inc. v. Islamic Republic of Iran, 734 F.3d 1175 (D.C. Cir.) (Rule 60(b)(4) timing and voidness)
- Baltia Air Lines, Inc. v. Transaction Mgt., Inc., 98 F.3d 640 (D.C. Cir.) (definition/examples of fraud on the court)
- Porter v. Nussle, 534 U.S. 516 (exhaustion requirement for prisoner suits under PLRA)
- Minneci v. Pollard, 565 U.S. 118 (scope of Bivens and availability of Bivens remedies)
- More v. Lew, 34 F. Supp. 3d 23 (D.D.C.) (fraud-on-the-court relief is rare)
- Bowie v. Maddox, 677 F. Supp. 2d 276 (D.D.C.) (fraud-on-the-court is not time-barred; standards)