Holmes v. United States, No. 16-1078 (8th Cir. 2018)Annotate this Case
In 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).