Williams v. Sullivan

Background

John T. Williams, proceeding without a lawyer, sued Richard Sullivan and other federal officials over matters arising from Williams’s criminal proceeding connected to a Federal Trade Commission enforcement action. The criminal proceeding resulted in Williams’s conviction on July 12, 2016. Judge Sullivan presided over Williams’s trial, imposed a five-year prison sentence and three years of supervised release, and later denied Williams’s request to vacate or set aside his conviction under 28 U.S.C. § 2255.

On January 14, 2025, the court dismissed Williams’s lawsuit with prejudice. It found the claims against Judge Sullivan frivolous and held that claim preclusion barred the claims against federal agents to the extent those claims had been decided on the merits in earlier cases. Claim preclusion is a rule that generally prevents a party from relitigating claims that were already decided, or that could have been raised, in an earlier case. The court also warned that continued frivolous filings could lead to sanctions.

Motion for Reconsideration

Williams moved under Federal Rule of Civil Procedure 60(b) for reconsideration of the January dismissal. Reconsideration is an extraordinary remedy generally reserved for situations involving an overlooked controlling legal decision or evidence, an intervening change in the law, newly available evidence, clear error, or manifest injustice. It is not ordinarily a chance to repeat arguments already rejected or present arguments that could have been raised earlier.

Williams again argued that Judge Sullivan had not been properly designated to oversee the § 2255 proceeding and that the alleged lack of designation made his rulings invalid. He also repeated his allegation that the warrant used to search his business premises was invalid because it lacked a signed certification page and was obtained through fraudulent pretenses. Williams submitted exhibits and requested judicial notice of materials concerning these arguments.

Ruling

Judge Engelmayer denied the Rule 60(b) motion. The court held that Williams had repeated arguments addressed in the original dismissal and had not identified controlling decisions or evidence that the court overlooked. The court also noted that Williams had previously appealed the ruling concerning his § 2255 proceeding, but the Second Circuit declined to issue a certificate of appealability, and that Williams had previously raised the designation argument in another Rule 60(b) motion.

The court reaffirmed that challenges to Judge Sullivan’s ruling in the § 2255 matter had to be pursued through an appeal rather than a separate lawsuit against Judge Sullivan. It also left undisturbed its conclusion that claim preclusion barred Williams’s claims arising from the criminal prosecution to the extent those claims had already been adjudicated on the merits. The clerk was directed to mail Williams a copy of the order, confirm service on the docket, close all pending motions, and leave the case closed.