Williams v. United States
- Richard Sullivan
- 1:20-cv-01554
- U.S. District Court · Southern District of New York
- 6
In Williams v. United States, Judge Sullivan denied Williams’s motions seeking relief from a supposedly void judgment.
John Todd Williams’s post-conviction motions were denied, and he was not permitted to proceed on an appeal without paying the required filing fees. The United States prevailed on the motions.
What happened
In Williams v. United States, John Todd Williams asked the court to undo his conviction and sentence through two motions claiming the judgment was invalid. He had been convicted of conspiracy to commit wire fraud and had previously lost a motion challenging his sentence.
Williams argued that the judge lacked authority to decide his earlier sentence challenge, that his conduct was not criminal wire fraud, and that errors involving the indictment, search warrants, due process, and sentencing required relief. The court said most of these arguments attacked the underlying conviction and had already been raised or decided, so they could not be brought again through this type of motion.
Judge Sullivan ruled that Williams had not shown the judge lacked authority to decide the earlier proceeding because federal law allowed him to continue serving as a district judge by designation. The court denied both motions, certified that any appeal would not be taken in good faith, and barred Williams from proceeding without paying the required filing fees.
The detailed version
- Williams v. United States · No. 1:20-cv-01554
- Richard Sullivan
- Aug. 8, 2024
Background
John Todd Williams, representing himself, filed two similar motions under Federal Rule of Civil Procedure 60(b)(4). That rule allows a court to provide relief from a final judgment when the judgment is void—that is, fundamentally invalid because of a lack of jurisdiction or a serious due-process problem. The motions concerned Williams’s conviction and sentence in the related criminal case, No. 14-cr-784 (RJS).
A jury found Williams guilty in July 2016 of conspiracy to commit wire fraud under 18 U.S.C. §§ 1343 and 1349. The court sentenced him principally to five years in prison followed by three years of supervised release. The appeals court affirmed his conviction and sentence. Williams later filed a motion under 28 U.S.C. § 2255, a procedure for asking the sentencing court to vacate or correct a federal sentence; that motion was denied, and the appeals court denied a certificate of appealability and dismissed the appeal.
Arguments and analysis
Williams’s Rule 60(b)(4) motions, dated June 8 and September 7, 2023, claimed that the judgment was void for lack of jurisdiction. He argued that:
- the judge should not have presided over the earlier § 2255 proceeding after becoming a circuit judge; - his conduct amounted at most to a civil violation of the Fair Debt Collection Practices Act, not criminal wire fraud; - the indictment was defective because it charged conspiracy to commit wire fraud rather than substantive wire fraud and did not identify a penalty provision for the conspiracy offense; - search warrants were fraudulent and invalid under the Fourth Amendment; and - various technical errors violated due process, including alleged problems with the warrants, missing inventory or return of seized items, a codefendant’s sentence, and reassignment of the criminal case.
The court held that the overwhelming majority of these arguments challenged Williams’s underlying criminal conviction rather than the integrity of the earlier § 2255 proceeding. Because Rule 60(b) cannot be used to relitigate issues already decided or to make another attempt to overturn the conviction, the court rejected those arguments as outside the proper scope of the motions.
The court treated Williams’s argument about the judge’s authority differently because it directly challenged the court’s authority in the earlier § 2255 proceeding. The court nevertheless rejected that argument. It relied on 28 U.S.C. §§ 291(b) and 296, which authorize temporary designation of a circuit judge to hold a district court and require the judge to perform the assigned judicial duties. The court also stated that circuit judges routinely continue handling matters assigned to them while they were district judges, including § 2255 motions. Williams did not identify authority showing that the designation was invalid, and the court found that his argument about the absence of a “Sitting by Designation” notation on a particular order was incorrect.
Disposition
The court denied Williams’s Rule 60(b) motions. It also certified under 28 U.S.C. § 1915(a)(3) that any appeal from the order would not be taken in good faith, so Williams could not proceed on appeal without paying the required filing fees. The clerk was directed to mail Williams a copy of the order and terminate the two pending motions.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.