Williams v. Koening

Background

Paul A. Williams, who was representing himself, had an earlier federal case challenging his assault conviction from the San Francisco County Superior Court. In that case, the court granted a stay so Williams could return to state court to exhaust judicial remedies for some claims. The court also administratively closed the case and instructed Williams to move to reopen it, lift the stay, and amend his petition within 30 days after completing exhaustion. The earlier case remained stayed and administratively closed; no judgment or final order had been entered.

Motions in This Action

The present action began when Williams filed a document titled “Petitioner’s Motion Pursuant to Fed. R. Civ. P. 60(b)(6)” without identifying an existing case number. Rule 60(b)(6) allows a court to provide relief from a judgment or order for an exceptional reason. The motion argued that errors had occurred in Williams’s state criminal case. After the clerk sent Williams a notice that he had not filed a proper pleading, Williams filed a motion to clarify or correct. He stated that the Rule 60(b)(6) motion concerned the earlier case and argued that the court had never officially notified him that the earlier case had been administratively closed.

Court’s Analysis and Rulings

The court denied the Rule 60(b)(6) motion. It held that a Rule 60(b) motion could not be used to attack a state criminal conviction, explaining that a person seeking to challenge the lawfulness of current custody must use a federal petition for a writ of habeas corpus.

The court granted the motion to clarify only in the sense that it considered the motion, but rejected the merits of Williams’s arguments. The court found that the earlier order’s title and text clearly stated that the case was administratively closed and that no separate official notice was required when the clerk carried out that instruction. The court also stated that, because the earlier case had no final order or judgment, it would not direct that the Rule 60(b)(6) motion be filed there.

The court dismissed this action because Williams was not entitled to relief from his state conviction through the Rule 60(b) motion. The dismissal was without prejudice to Williams’s pursuing habeas relief in the earlier case. The court stated that, if Williams had completed exhausting his state-court remedies, he could file in that earlier case a motion to reopen, lift the stay, and amend his petition. The clerk was directed to close the file.