United States v. Springer, 875 F.3d 968

Background

Lindsey Springer, a federal prisoner, filed a post-conviction “Motion to Enjoin” alleging government fraud on the conviction court (prosecutors lacked authorization). The district court summarily denied the motion as frivolous.
Springer previously filed a § 2255 motion challenging his conviction; that initial § 2255 was resolved and a COA was denied.
The government moved to dismiss Springer’s new motion as an unauthorized second or successive § 2255 petition, arguing AEDPA’s pre-filing authorization and COA requirements apply.
Springer argued his fraud-on-the-court claim is equitable and therefore not subject to AEDPA limits, relying principally on McQuiggin v. Perkins.
The Tenth Circuit panel concluded Baker controls: fraud-on-the-court claims that attack the underlying conviction are treated as second-or-successive § 2255 motions and thus require circuit authorization/COA.
The court denied a COA (finding a plain procedural/jurisdictional bar because the district court lacked jurisdiction to adjudicate an unauthorized successive petition), dismissed the appeal, and instructed the district court to vacate its decision.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a fraud-on-the-court motion challenging a conviction is exempt from AEDPA’s second-or-successive limits	Springer: fraud-on-the-court is an equitable, traditional power that McQuiggin preserves against AEDPA limits, so AEDPA authorization/COA are unnecessary	Government: the motion attacks the underlying conviction and is therefore a second-or-successive § 2255 motion subject to AEDPA authorization/COA requirements	Held: Motion is a second-or-successive § 2255 petition governed by AEDPA; McQuiggin does not overrule Baker
Whether McQuiggin v. Perkins supersedes United States v. Baker to allow fraud-on-the-court claims to bypass AEDPA limits	Springer: McQuiggin’s emphasis on preserving equitable authority means fraud-on-the-court claims escape AEDPA’s restrictions	Government: McQuiggin addressed actual-innocence gateway for initial petitions and expressly acknowledged Congress constrained second-or-successive petitions; it does not invalidate Baker	Held: McQuiggin does not contradict or invalidate Baker; it is limited to actual-innocence in first petitions
Whether a COA is required and should issue for Springer’s appeal	Springer: treated the notice of appeal as sufficient and argued COA unnecessary because claim is equitable	Government: COA required; absent a substantial showing of denial of a constitutional right, no COA	Held: COA required and denied—Springer failed to make the requisite substantial showing
Effect of district court deciding the motion on the merits without circuit authorization	Springer: district court’s merits ruling should stand	Government: district court lacked subject-matter jurisdiction to decide an unauthorized successive § 2255 motion; it should have dismissed or transferred for authorization	Held: District court lacked jurisdiction to reach the merits; denial of COA affirmed and appeal dismissed; district court instructed to vacate its merits decision

Key Cases Cited

United States v. Baker, 718 F.3d 1204 (10th Cir. 2013) (held fraud-on-the-court claims that attack a conviction are second-or-successive § 2255 petitions)
McQuiggin v. Perkins, 569 U.S. 383 (2013) (preserved actual-innocence "miscarriage of justice" equitable gateway for initial habeas petitions under AEDPA)
Slack v. McDaniel, 529 U.S. 473 (2000) (certificate of appealability standard and two-part test for procedural rulings)
Hazel-Atlas Glass Co. v. Hartford-Empire Co., 322 U.S. 238 (1944) (recognition of courts’ inherent power to set aside judgments obtained by fraud on the court)
Chambers v. NASCO, Inc., 501 U.S. 32 (1991) (Congress may limit courts’ inherent powers when it provides a clear statutory command)
United States v. Nelson, 465 F.3d 1145 (10th Cir. 2006) (district court lacks jurisdiction to adjudicate unauthorized second-or-successive § 2255 motions)