Williams v. United States
- Richard Sullivan
- 1:20-cv-01554
- U.S. District Court · Southern District of New York
- 4
In Williams v. United States, Judge Sullivan denied Williams’s motions to correct, recuse, challenge his case, and pursue the remaining motions.
John Todd Williams’s motions were denied. His pending challenges to the arrest, detention, conviction, warrants, indictment, and judicial reassignments could not be decided while the related appeal was pending, and he could not pursue an appeal from this order without paying the filing fee.
What happened
In Williams v. United States, John Todd Williams filed a motion seeking to correct an earlier order and a motion asking the judge to step aside. He also filed motions challenging his arrest, detention, conviction, warrants, indictment, and judicial reassignments while an appeal of the earlier order was pending.
The court denied the motion to correct because it was too late as a reconsideration request and did not show the exceptional circumstances required for relief under Rule 60(b). It denied the recusal motion because Williams mainly challenged the court’s earlier rulings, which generally are not grounds for recusal. It denied the other motions for lack of authority to decide them while the appeal was pending.
Judge Sullivan denied all of the pending motions and certified that any appeal from this order would not be taken in good faith, so Williams could not proceed without paying the filing fee.
The detailed version
- Williams v. United States · No. 1:20-cv-01554
- Richard Sullivan
- Jan. 21, 2025
Background
John Todd Williams had an appeal pending in the United States Court of Appeals for the Second Circuit from an August 8, 2024 order that denied his motions under Rule 60(b), a rule allowing a court to provide relief from a judgment or order in limited circumstances. While that appeal was pending, Williams filed two motions dated September 17, 2024: a “Motion to Clarify and Correct” the August 8 order and a motion asking Judge Richard J. Sullivan to recuse, or step aside. Williams also filed motions challenging the legality of his arrest, detention, and conviction, including challenges to the search and arrest warrants, the indictment, and judicial reassignments.
Motion to Correct
The court denied Williams’s Motion to Correct. To the extent the motion sought reconsideration, the court held that it was untimely under Local Civil Rule 6.3, which requires such motions to be filed within fourteen days of the challenged order. The court also stated that, even if it treated the filing as a new Rule 60(b) motion challenging the denial of Williams’s earlier Rule 60(b) motions, Williams had not shown the exceptional circumstances required for that extraordinary relief.
Recusal Motion
The court also denied Williams’s Recusal Motion. It found that the motion largely repeated the arguments in the Motion to Correct. The court further held that the alleged grounds for recusal were mainly challenges to the court’s judicial rulings, and that such rulings almost never provide a valid basis for finding judicial bias or partiality.
Other Motions and Pending Appeal
The court denied for lack of jurisdiction Williams’s other motions challenging his arrest, detention, and conviction. The court explained that filing a notice of appeal generally transfers control over the matters involved in the appeal to the appellate court. It concluded that the August 8, 2024 order on appeal had already resolved substantially similar arguments. The court advised that any additional motions concerning the questions decided in that order would likewise be denied without prejudice for lack of jurisdiction until the Second Circuit resolved the appeal.
Disposition
The order states that Williams’s September 17, 2024 Motion to Correct and Recusal Motion were denied, and that the remainder of his pending motions were likewise denied. The court also certified under 28 U.S.C. § 1915(a)(3) that any appeal from this order would not be taken in good faith, meaning Williams could not pursue such an appeal without paying the filing fee. Judge Sullivan directed the Clerk of Court to mail Williams a copy of the order and terminate the listed motions on the criminal and civil dockets.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.