United States v. Roderick Williams, 56 F.4th 366

Williams was convicted in 2004 of drug and gun offenses after DNA evidence (blood on a bag) tested by SBI analyst Brenda Bissette linked him to the crime.
He filed a timely 28 U.S.C. § 2255 ineffective-assistance claim in 2008 arguing counsel failed to obtain independent testing of the blood; the district court denied relief in 2012 and this Court affirmed the conviction on direct appeal.
In 2016 Williams filed a Federal Rule of Civil Procedure 60(b)(3) motion alleging the Government made material misrepresentations about the reliability of the DNA evidence and that newly obtained SBI documents showed Bissette committed handling and testing errors.
The district court treated the filing as successive and dismissed; this Court held it was a Rule 60(b)(3) motion and remanded for timeliness determination. On remand the district court found Williams’s Rule 60(b)(3) motion untimely and denied equitable tolling; Williams appealed.
The Fourth Circuit held, as a matter of law, that Rule 60(b)(3)’s one-year time limit is a mandatory claim-processing rule that cannot be equitably tolled and affirmed the denial of Williams’s motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rule 60(b)(3)’s one-year time limit is subject to equitable tolling	Williams: extraordinary circumstances (Government misrepresentations, newly obtained SBI documents about Bissette) justify equitable tolling of the >1-year delay	Government: Rule 60(b)(3)’s deadline is a mandatory claim-processing rule; Rule 6 forbids extensions and other rules show inflexibility, so tolling is unavailable	The one-year limit is mandatory and cannot be equitably tolled; Williams’s Rule 60(b)(3) motion was untimely and dismissal affirmed
Whether court may reach merits of Williams’s fraud/misrepresentation claim	Williams: substantive claim shows Government misconduct that prevented fair presentation	Government: merits not reached if timeliness bars relief; also contested merits	Court did not reach merits because timeliness dispositive (and Williams forfeited Rule 60(b)(6) argument)

Nutraceutical Corp. v. Lambert, 139 S. Ct. 710 (2019) (Supreme Court held a procedural rule was mandatory where the rules show clear intent to preclude tolling)
United States v. Marsh, 944 F.3d 524 (4th Cir. 2019) (held criminal appeal deadline mandatory and explained rule-text relationships dictate flexibility)
United States v. McRae, 793 F.3d 392 (4th Cir. 2015) (Rule 60(b) timeliness is an affirmative defense, not jurisdictional)
In re Cook Med., Inc., 27 F.4th 539 (7th Cir. 2022) (concluded Rule 60(b) one-year limit is mandatory and not tollable regardless of excusable neglect arguments)
In re Rumsey Land Co., LLC, 944 F.3d 1259 (10th Cir. 2019) (Rule 60(b)’s one-year time limit is absolute and not subject to tolling)
Warren v. Garvin, 219 F.3d 111 (2d Cir. 2000) (described Rule 60(b) one-year limit as absolute)
Pioneer Inv. Servs. Co. v. Brunswick Assocs. Ltd. P’ship, 507 U.S. 380 (1993) (Rule 60(b)(6) is mutually exclusive from other subsections and available only for extraordinary circumstances)