Simpson v. Rios
- John Tunheim
- 0:18-cv-00381
- U.S. District Court · District of Minnesota
- 4
In Simpson v. Rios, Judge Tunheim denied Simpson’s motion to change judgment because it raised new arguments and showed no legal error.
Louis Simpson’s request to change the earlier denial of his habeas petition was denied; the respondent’s position was left undisturbed.
What happened
Louis Simpson, a federal prisoner representing himself, asked the court to change its earlier denial of his petition challenging his custody. He argued that a magistrate judge in an earlier related proceeding was biased for refusing to admit a business-record report.
The court said Simpson’s motion raised new arguments that he could have made earlier. The court also considered the arguments on their merits and found that refusing to admit the report did not show bias or a serious error affecting the proceedings. The court separately denied Simpson’s request to amend factual findings because the case had not been tried on facts requiring such findings.
In Simpson v. Rios, Judge John R. Tunheim denied the Motion to Alter or Amend Judgment. The court found no clear legal error in its earlier order.
The detailed version
- Simpson v. Rios · No. 0:18-cv-00381
- John Tunheim
- Sept. 24, 2018
Background
Louis Simpson, a federal prisoner proceeding without a lawyer, filed a motion under Federal Rule of Civil Procedure 59(e) asking the court to alter or amend its earlier judgment denying his petition under 28 U.S.C. § 2241. Simpson also asked the court to amend its findings under Federal Rule of Criminal Procedure 52(b) and Federal Rule of Civil Procedure 52(b).
Simpson argued that the court had made a clear legal error by failing to consider his claim that a magistrate judge in an earlier related proceeding was biased. He claimed that the magistrate judge deliberately refused to admit a report from the Texas Secretary of State’s business records, which Simpson said showed that the alleged victim named in his indictment did not exist when he committed the offenses for which he was convicted.
Court’s reasoning
The court explained that a Rule 59(e) motion cannot be used to introduce new evidence, present new legal theories, or raise arguments that could have been made before judgment. Although Simpson had previously argued that the magistrate judge ignored his evidence, the court found that his new claims—that the conduct showed bias, constituted structural error, and made another post-conviction remedy inadequate or ineffective—were not raised in his original petition. The court therefore found that the motion failed on procedural grounds.
The court also ruled that the motion would fail on the merits even if it were proper under Rule 59(e). It found that the magistrate judge’s refusal to admit the report did not demonstrate bias. The court noted that the report had been deemed irrelevant to the outcome and that the earlier claim based on the report had been found procedurally barred and without merit. The court further held that alleged bias by a magistrate judge during post-conviction proceedings was not a “structural error”—an error affecting the basic framework of a trial.
The court denied Simpson’s request under Federal Rule of Criminal Procedure 52(b) because that rule did not apply to his motion. It denied the request under Federal Rule of Civil Procedure 52(b) because the court had not tried the case or made factual findings of the type covered by that rule.
Disposition
Judge John R. Tunheim found no clear legal error in the court’s prior order and ordered that Simpson’s Motion to Alter or Amend Judgment was DENIED.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.