Keith v. United States of America
- Alison Nathan
- 1:20-cv-04410
- U.S. District Court · Southern District of New York
- 1
In David Keith v. United States, Judge Nathan denied Keith’s motion, denied appeal fee-waiver status and a certificate of appealability, and closed the case.
David Keith’s motion was denied; the United States obtained judgment, and Keith’s civil action was closed. His appeal-related fee-waiver request and certificate of appealability were also denied.
What happened
In David Keith v. United States, David Keith asked the court for relief under Rule 60(b), a rule that allows certain judgments or orders to be challenged. The judgment says the court relied on a September 26, 2025 memorandum opinion and order.
The court denied Keith’s motion. It stated that his first claim lacked substantive merit and that his remaining claims were outside Rule 60(b)’s scope. The judgment also says the court denied fee-waiver status for an appeal and denied a certificate of appealability.
Judge Alison Nathan’s ruling entered judgment for the United States and closed Keith’s civil case. The court also found that any appeal would not be taken in good faith and that Keith had not made the required substantial showing of a constitutional-right violation.
The detailed version
- Keith v. United States of America · No. 1:20-cv-04410
- Alison Nathan
- Sept. 29, 2025
Background
The judgment concerns David Keith’s motion in a matter also associated with docket numbers 20 Civ. 4410 (GHW) and 15 Cr. 827 (GHW). The judgment states that the court’s reasons appear in a memorandum opinion and order dated September 26, 2025. That memorandum is not included in the provided text.
Ruling on the Motion
The court denied Keith’s motion. The judgment states that Keith’s first claim lacked substantive merit and that his remaining claims fell outside the scope of Rule 60(b), a rule governing certain requests for relief from a judgment or order.
Appeal-Related Rulings and Disposition
The court certified under 28 U.S.C. § 1915(a)(3) that an appeal would not be taken in good faith and therefore denied fee-waiver status for purposes of an appeal. It also denied a certificate of appealability under 28 U.S.C. § 2253, stating that Keith had not made a substantial showing that a constitutional right had been denied.
Judge Alison Nathan’s judgment entered judgment for the United States. The judgment states that Keith’s civil action, No. 1:25-cv-3298-GHW, was closed.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.