Holmes v. United States, No. 16-1078 (8th Cir. 2018)
Annotate this CaseIn 2011, movant's 2006 sentence for drug and firearm possession was vacated. In this appeal, movant challenged the district court's denial of a certificate of innocence. The Eighth Circuit affirmed, holding that the district court's decision to credit a witness and find that movant did not prove his actual innocence was not completely capricious and without rational basis. The court also held that the district court did not abuse its discretion when it chose to rely on the trial record and other relevant facts presented by affidavits rather than conducting an evidentiary hearing. Finally, the district court did not err by denying a motion for relief from judgment under Federal Rule of Civil Procedure 60(b)(2) and (6).
Court Description: Shepherd, Author, with Wollman and Erickson, Circuit Judges] Civil case - Motion for a Certificate of Innocence. After Holmes's federal sentence was vacated under Section 2255 based on illegal activities by the officers involved in his arrest, Holmes moved for a certificate of innocence pursuant to 28 U.S.C. Sections 1495 and 2513; held, the district court did not err in denying the motion as the district court was free to credit either of two contradictory witnesses; as the testimony from the witness the court credited could have established Holmes's guilt, the court decision that Holmes had not proven his innocence was not completely capricious or without rational basis; in making that determination, the court could rely primarily on the trial record and other relevant facts presented by affidavit and did not need to conduct an evidentiary hearing; Holmes's favorable verdict in his Section 1983 action against the police officers did not undermine the credibility of the witness the court credited in denying the motion for a certificate of innocence; while the jury verdict in the Section 1983 was a piece of new evidence, it was not evidence, if presented in a new certificate of innocence proceeding, which would probably produce a new result, and the court did not err in denying Holmes's Rule 60(b)(2) and (6) motion.
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