United States v. Williams, No. 14-5070 (10th Cir. 2015)
Annotate this CaseDefendant-appellee Jeffrey Williams filed a motion seeking to withdraw his guilty plea to various drug and firearm charges based on newly discovered evidence. Specifically, defendant submitted affidavits in support of his claim that his guilty plea was involuntarily entered because the law enforcement officers investigating his case planted evidence, gave false testimony, and used threats and intimidation to suborn perjury from other witnesses. After conducting an evidentiary hearing, the district court vacated defendant's convictions, concluding that the officers had perpetrated a fraud on the court and that vacating defendant's convictions was necessary to correct the fraud and to prevent a miscarriage of justice. The government appealed, arguing the district court lacked jurisdiction over defendant's motion due to his failure to first obtain certification from the Tenth Circuit, as required by 28 U.S.C. 2255, permitting him to file a second or successive petition for habeas corpus relief. After review, the Tenth Circuit concluded that the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA) limited the courts' power to correct fraud on the court and to prevent a miscarriage of justice when the court vacates a conviction in response to a second or successive habeas petition. "Although a district court may invoke these powers sua sponte, the district court here acted on Mr. Williams's motion to withdraw his guilty plea, which is a second or successive petition." The Court therefore reversed the district court's order vacating defendant's conviction for lack of jurisdiction. But the Tenth Circuit exercised its discretion to treat defendant's appellate brief as a request to file a second or successive motion under 28 U.S.C. 2255(h), and granted that request in part.
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