United States v. Williams
2015 U.S. App. LEXIS 10631
| 10th Cir. | 2015Background
- Jeffrey D. Williams pled guilty (1998) to methamphetamine conspiracy, two drug-possession counts, and a firearm offense; he was sentenced to 420 months. He later filed multiple §2255 collateral attacks.
- In 2010–2012 Williams alleged Tulsa police and certain informants planted evidence, suborned perjury, and coerced testimony; he attached new affidavits and sought to withdraw his guilty plea.
- The district court treated Williams’ filing as invoking its inherent authority (Rule 60(d)(3)) to set aside a judgment for fraud on the court, appointed counsel, held an evidentiary hearing, and vacated the convictions.
- The government appealed, arguing the Motion was a second or successive §2255 petition and the district court lacked jurisdiction because Williams had not obtained the court-of-appeals’ certification required by AEDPA (28 U.S.C. §2255(h)).
- The Tenth Circuit reversed: it held Williams’ Motion was a second or successive §2255 petition, AEDPA limits district courts’ power to grant relief on uncertified successive petitions (including fraud-on-the-court or miscarriage-of-justice claims), and the district court had acted on Williams’ motion (not truly sua sponte).
- The court nonetheless exercised discretion to authorize, in part, a successive §2255 filing limited to the firearm conviction (finding Williams made a prima facie showing under §2255(h)(1) as to that count) and remanded with instructions to dismiss for lack of jurisdiction as to the other claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Williams’ Motion was a second or successive §2255 motion | Williams: his claim was not a successive habeas because the corruption-related defect ripened after his first petition (Weathersby exception) | Government: motion attacks underlying conviction and therefore is successive under AEDPA | Held: Motion is a second/successive §2255 motion; Weathersby exception inapplicable because the factual basis preexisted the first petition |
| Whether AEDPA bars district courts from acting on uncertified successive petitions that allege fraud on the court | Williams: district court had inherent authority to correct fraud and could act despite AEDPA; court acted sua sponte | Government: AEDPA’s certification requirement (§2255(h)) limits district courts’ jurisdiction to consider uncertified successive petitions, even when alleging fraud | Held: AEDPA limits the court’s inherent powers in this context; district court lacked jurisdiction to grant relief on Williams’ motion without appellate certification |
| Whether the district court actually acted sua sponte (which would avoid AEDPA limits) | Williams/district court: the court invoked its inherent authority sua sponte to correct fraud on the court | Government: the district court considered claims and evidence from Williams’ motion, so it acted on the successive application | Held: The court acted on Williams’ successive application (considered his new claims/evidence), so its action was governed by AEDPA and not a true sua sponte act |
| Whether Williams made the §2255(h)(1) showing to obtain permission to file a successive petition | Williams: newly discovered evidence and witness recantations establish actual innocence by clear and convincing evidence | Government: (responded on jurisdictional ground; merits largely not briefed) | Held: Court grants permission in part — authorizes successive §2255 as to the firearm conviction (prima facie showing met) but denies authorization for conspiracy and drug-possession convictions (clear-and-convincing standard not satisfied) |
Key Cases Cited
- Chambers v. NASCO, Inc., 501 U.S. 32 (1991) (discusses courts’ inherent equitable powers including fraud-on-the-court authority)
- Hazel-Atlas Glass Co. v. Hartford-Empire Co., 322 U.S. 238 (1944) (fraud on the court can void judgments and is grounds for relief outside ordinary procedural bars)
- Gonzalez v. Crosby, 545 U.S. 524 (2005) (recasting filings as Rule 60 motions cannot evade AEDPA when they attack the merits of prior habeas determinations)
- McQuiggin v. Perkins, 569 U.S. 383 (2013) (AEDPA cannot displace courts’ traditional equitable authority except by the clearest command; discusses actual-innocence/miscarriage-of-justice doctrines)
- Calderon v. Thompson, 523 U.S. 538 (1998) (test for when a court truly acts sua sponte vs. acting on a successive habeas application)
- United States v. Baker, 718 F.3d 1204 (10th Cir. 2013) (a motion alleging fraud on the conviction court is a successive §2255 petition and must meet AEDPA gatekeeping)
- United States v. Nelson, 465 F.3d 1145 (10th Cir. 2006) (describes when postjudgment filings are treated as successive §2255 motions; district court lacks jurisdiction over uncertified successive motions)