Wright v. Warden, Riverbend Maximum Sec. Inst., No. 13-6573 (6th Cir. 2015)
Annotate this CaseIn 1985, a Tennessee state jury convicted Wright of two counts of pre-meditated murder in the first degree. Wright was sentenced to life imprisonment for one and sentenced to death for the other. The Tennessee Supreme Court affirmed Wright’s convictions and sentences on direct appeal. Three sets of unsuccessful state post-conviction proceedings followed. In 1999, Wright sought federal habeas relief with appointed counsel. The Sixth Circuit affirmed denial. In 2013, Wright moved from judgment under Rule 60(b), asserting that Martinez, a 2012 Supreme Court decision, changed the law of procedural default such that, if his case were reopened, the court could reach the merits of claims previously dismissed as procedurally defaulted. The court closed the action without prejudice until the Supreme Court’s 2013 issuance of Trevino, and later denied Wright’s renewed Rule motion. The Sixth Circuit affirmed. Rule 60(b)(6) relief is available only in “exceptional or extraordinary circumstances,” and Wright did not demonstrate such circumstances. Neither Martinez nor Trevino sufficiently changed the balance of the factors for consideration under Rule 60(b)(6) to warrant relief. Those decisions were “not a change in the constitutional rights of criminal defendants, but rather an adjustment of an equitable ruling by the Supreme Court as to when federal statutory relief is available.”
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