American Bar Association
Media Alerts
Media Alerts - Paul Satterfield v. District Attorney Philadelphia - Third Circuit
Decrease font size
Increase font size
September 27, 2017
  Paul Satterfield v. District Attorney Philadelphia - Third Circuit
Headline: Third Circuit Articulates New Analysis for Rule 60(b)(6) Motions Premised on a Change in Decision Law, and Finds That a Showing of Actual Innocence Weighs Heavily in Favor of Habeas Corpus Petitioners' Ability to Litigate Their Constitutional Claims Despite Certain Procedural Bars

Area of Law: Federal Rules of Civil Procedure and Habeas Corpus

Issues Presented: Whether a change in decisional law, either alone or in combination with other equitable factors, was sufficient basis for invoking relief from final judgment under Rule 60(b)(6), to allow an appellant to raise an otherwise time-barred valid claim that trial counsel was ineffective?

Brief Summary: Despite repeatedly asserting his innocence, Paul Satterfield was convicted of first degree murder in 1985 and sentenced to life in prison. After years of direct and collateral litigation, Satterfield appeared to emerge victorious when the District Court, acting on his federal habeas petition, found that his ineffective assistance of counsel claim was meritorious. But the Third Circuit reversed the order granting habeas relief, after finding that Satterfield's petition was barred by Antiterrorism and Effective Death Penalty Act's ("AEDPA") statute of limitations. On remand, the District Court dismissed Satterfield's petition. In 2014, Satterfield 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 v. Perkins (2013) was a change in decisional law that served as an extraordinary circumstance upon which Rule 60(b)(6) relief may issue. McQuiggin held that "actual innocence, if proved, serves as a gateway through which a petitioner may pass" to overcome an untimely petition under AEDPA. However, the District Court denied Satterfield's Rule 60(b)(6) motion after determining that the decision in McQuiggin was not an extraordinary circumstance. On appeal, the Third Circuit considered whether McQuiggin, either alone or in combination with other equitable factors, was sufficient to invoke relief from final judgment under Rule 60(b)(6) to allow an appellant to raise an otherwise time-barred valid claim that trial counsel was ineffective.

The Third Circuit vacated the District Court's order, citing precedent which held that changes in decisional law may - when paired with certain circumstances - justify Rule 60(b)(6) motion relief. The Third Circuit explained that a district court addressing a Rule 60(b)(6) motion premised on a change in decisional law must examine the full panoply of equitable circumstances in the particular case before rendering a decision. The Third Circuit found that the District Court in Satterfield's case failed to undertake this required equitable analysis; thus, the court remanded the case for proper consideration.

The Third Circuit concluded by further instructing the District Court that on remand the nature of the change in decisional law must be weighed appropriately in the analysis of pertinent equitable factors. It emphasized that McQuiggin implicated the foundational principle of avoiding the conviction of an innocent person and attempted to prevent such a mistake through "the fundamental miscarriage of justice exception." Accordingly, the Third Circuit stated that if Satterfield could make the required credible showing of actual innocence to avail himself of "the fundamental miscarriage of justice exception," equitable analysis would weigh heavily in favor of deeming McQuiggin's change in law an exceptional circumstance justifying Rule 60(b)(6) relief. The Third Circuit then clarified that the nature of the change of law cannot be divorced from that analysis: Satterfield's ability to show actual innocence should not be case determinative. The District Court should weigh all of the equitable factors as guided by precedent.

Extended Summary: Despite repeatedly asserting his innocence, Paul Satterfield was convicted of first degree murder in 1985 and sentenced to life in prison. After years of direct and collateral litigation, Satterfield appeared to emerge victorious when the District Court, acting on his federal habeas petition, found that his ineffective assistance of counsel claim was meritorious. But in an earlier appeal the Third Circuit reversed the order granting habeas relief, after finding that Satterfield's petition was barred by Antiterrorism and Effective Death Penalty Act's ("AEDPA") statute of limitations. On remand, the District Court dismissed Satterfield's petition. In 2014, almost 30 years after his conviction, Satterfield 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 v. Perkins (2013) was a change in decisional law that served as an extraordinary circumstance upon which Rule 60(b)(6) relief may issue. McQuiggin held that "actual innocence, if proved, serves as a gateway through which a petitioner may pass" to overcome an untimely petition under AEDPA. However, the District Court denied Satterfield's Rule 60(b)(6) motion after determining that McQuiggin was not an extraordinary circumstance. On appeal, the Third Circuit examined whether McQuiggin, either alone or in combination with other equitable factors, was sufficient to invoke relief from final judgment under Rule 60(b)(6) to allow an appellant to raise an otherwise time-barred valid claim that trial counsel was ineffective.

The Third Circuit began its analysis by stating that Rule 60(b) provides litigants with a mechanism by which they may obtain relief from a final judgment "under a limited set of circumstances including fraud, mistake, and newly discovered evidence." Next, it explained that despite the open-ended nature of the provision, a district court may grant relief under Rule 60(b)(6) only in "extraordinary circumstances where, without such relief, an extreme and unexpected hardship would occur." The Third Circuit then considered Satterfield's assertion that a change in relevant decisional law occurring after his petition had been denied was an extraordinary circumstance upon which his Rule 60(b)(6) relief may issue. First, the Third Circuit acknowledged that Satterfield properly characterized McQuiggin as effecting a change in decisional law, since prior to McQuiggin, the Court had never affirmatively held that a showing of actual innocence could serve as an equitable exception to AEDPA's statute of limitations. Second, the Third Circuit determined whether the change in law effected by McQuiggin could properly serve as the basis of a Rule 60(b)(6) motion. The Third Circuit clarified that although change in decisional law alone has "rarely" constituted "extraordinary circumstances" for purposes of a Rule 60(b) motion, the Court has historically refrained from imposing any per se or bright-line rule that a particular change in law is never an extraordinary circumstance. Instead, the Third Circuit stated it has adhered to a "case-dependent analysis" rooted in equity, that manifests as a "flexible, multifactor approach to Rule 60(b)(6) motions," by taking 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. Accordingly, the Third Circuit held that whenever a petitioner bases a Rule 60(b)(6) motion on a change in decisional law, the court should evaluate the nature of the change along with all of the equitable circumstances and clearly articulate the reasoning underlying its ultimate determination. "Whenever a petitioner bases a Rule 60(b)(6) motion on a change in decisional law, the court should evaluate the nature of the change along with all of the equitable circumstances and clearly articulate the reasoning underlying its ultimate determination." The Third Circuit found that the District Court in Satterfield's case failed to articulate this requisite equitable analysis, and thus it remanded the case for proper consideration.

The Third Circuit concluded by further instructing the District Court that on remand, the nature of the change in decisional law must be weighed appropriately in the analysis of pertinent equitable factors. The Court emphasized that the values encompassed by the fundamental-miscarriage-of-justice exception and which drove the Supreme Court's decision in McQuiggin could not be divorced from other aspects of the Rule 60(b)(6) inquiry. More specifically, it explained that Third Circuit precedent requires a weighing of all the equitable factors at play in a particular case, and the nature of the change in law itself is highly relevant to that analysis. According to the Third Circuit, McQuiggin illustrated that where a petitioner makes an adequate showing of actual innocence, the interest in avoiding the wrongful conviction of an innocent person weighs heavily in favor of permitting the petitioner to pursue his constitutional claims in spite of the statute-of-limitations bar. The Third Circuit further explained that because society's "interest in avoiding the wrongful conviction of an innocent person" is so deeply embedded within our justice system, if a petitioner can make a showing of actual innocence, McQuiggin's change in law is almost certainly an exceptional circumstance. Accordingly, the Third Circuit determined that a proper demonstration of actual innocence by Satterfield could permit Rule 60(b)(6) relief unless the totality of equitable circumstances ultimately weigh heavily in the other direction. The Court then noted several other equitable factors that might come into play, including Satterfield's meritorious ineffective- assistance-of-counsel claim. However, the Court also warned that a credible showing of actual innocence is a "burdensome task" that can be met only by showing that in light of new evidence no reasonable juror could have found the defendant guilty beyond a reasonable doubt.

Ultimately, the Third Circuit vacated the District Court's order with respect to the denial of Satterfield's request for Rule 60(b)(6) relief, and remanded the case for reconsideration of the whether the change of law wrought by McQuiggin, combined with the other circumstances of the case, merited relief under Rule 60(b)(6).

The full opinion can be found at http://www2.ca3.uscourts.gov/opinarch/152190p.pdf

Panel: Ambro, Vanaskie, and Restrepo, Circuit Judges

Argument Date: March 27, 2017

Date of Issued Opinion: September 26, 2017

Docket Number: No. 15-2190

Decided: Vacated and remanded

Case Alert Author: Brooke Hutchins

Counsel: Aren K. Adjoian, Esq. [ARGUED), Arianna J. Freeman, Esq., Counsel for Appellant; Susan E. Affronti, Esq., Simran Dhillon, Esq. [ARGUED], Counsel for Appellees

Author of Opinion: Circuit Judge Vanaskie

Circuit: Third Circuit

Case Alert Circuit Supervisor: Professor Mark Rahdert

    Posted By: Susan DeJarnatt @ 09/27/2017 01:00 PM     3rd Circuit  

FuseTalk Enterprise Edition - © 1999-2018 FuseTalk Inc. All rights reserved.

Discussion Board Usage Agreement

Back to Top