Law School Case Brief
Satterfield v. DA Phila. - 872 F.3d 152 (3d Cir. 2017)
The United States Court of Appeals for the Third Circuit's Cox decision, rendered almost ten years after the Gonzalez decision, confirms that the Third Circuit has not embraced any categorical rule that a change in decisional law is never an adequate basis for Fed. R. Civ. P. 60(b)(6) relief. Instead, the Third Circuit has consistently taken the position that intervening changes in the law rarely justify relief from final judgments under 60(b)(6). Rather than impose any per se or bright-line rule that a particular change in law is never an extraordinary circumstance, the court adheres to a case-dependent analysis rooted in equity. That analysis manifests as a flexible, multifactor approach to Rule 60(b)(6) motions that takes into account all the particulars of a movant's case, even where the proffered ground for relief is a post-judgment change in the law.
Despite repeatedly asserting his innocence, defendant Paul Satterfield was convicted of first degree murder in 1985 and sentenced to life in prison. After many years of direct and collateral litigation, defendant appeared to emerge victorious when the District Court, acting on his habeas petition, found that his ineffective assistance of counsel claim was meritorious. But Satterfield's hopes for post-conviction relief were short-lived, as this appellate court reversed the order granting habeas relief after finding that his petition was barred by AEDPA's statute of limitations. Satterfield's fight was revived in 2013 when the United States Supreme Court handed down its decision in McQuiggin v. Perkins, 569 U.S. 383, 133 S. Ct. 1924, 185 L. Ed. 2d 1019 (2013). Approximately 30 years after Satterfield's arrest in connection with Bryant's murder, he filed a motion with the District Court under Federal Rule of Civil Procedure 60(b)(6) seeking relief from the judgment dismissing his habeas petition. Satterfield argued that the Supreme Court's holding in McQuiggin was a change in decisional law that served as an extraordinary circumstance upon which Rule 60(b)(6) relief may issue.
Did the ruling in the McQuiggin serve as an extraordinary circumstance upon which Rule 60(b)(6) relief may issue?
Satterfield properly characterizes McQuiggin as effecting a change in our decisional law. Prior to McQuiggin, the Third Circuit had never affirmatively held that a showing of actual innocence could serve as an equitable exception to AEDPA's one-year statute of limitations. McQuiggin allows a petitioner who makes a credible showing of actual innocence to pursue his or her constitutional claims even in spite of AEDPA's statute of limitations by utilizing the fundamental-miscarriage-of-justice exception—an exception "grounded in the 'equitable discretion' of habeas courts to see that federal constitutional errors do not result in the incarceration of innocent persons." The values encompassed by the fundamental-miscarriage-of-justice exception and which drive the Supreme Court's decision in McQuiggin cannot be divorced from the Rule 60(b)(6) inquiry. Thus, the miscarriage-of-justice exception and McQuiggin's holding more broadly will not be applicable to Satterfield's case if he cannot make a proper showing of actual innocence, and the District Court must determine whether such a showing has been made as a threshold matter. We leave this inquiry entirely to the District Court on remand, and recognize that the issue may require an evidentiary hearing during which other equitable factors may come into play.
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