Rodriguez v. United States
- Charles Haight
- 1:14-cv-04628
- U.S. District Court · Southern District of New York
- 5
In Rodriguez v. United States, Senior Judge Haight treated two prisoners’ Johnson and Davis claims as a Rule 60(b) motion without deciding their merits.
Jaime Rodriguez and Steven Camacho, who were proceeding without lawyers; the Federal Defenders of New York; and the United States as respondent.
What happened
Rodriguez v. United States and Camacho v. United States involved two pro se prisoners who jointly sought to reopen earlier challenges to their federal convictions and sentences. They argued that the court had not addressed claims based on Supreme Court decisions concerning certain sentencing provisions.
The court treated their application as a motion under Rule 60(b), which can reopen a prior proceeding when the issue concerns the fairness of that proceeding. It did not decide whether either prisoner was entitled to have his conviction or sentence vacated.
Senior District Judge Haight vacated an earlier order, directed that the application be filed in the consolidated proceedings, administratively closed four newly opened civil cases, and set steps for possible briefing by the Federal Defenders and the United States.
The detailed version
- Rodriguez v. United States · No. 1:14-cv-04628
- Charles Haight
- Nov. 18, 2019
Background
Jaime Rodriguez and Steven Camacho, both appearing without lawyers, filed a joint motion seeking to reopen their earlier proceedings and vacate their convictions and sentences under 28 U.S.C. § 2255. Rodriguez’s earlier proceeding challenged the legality of his sentence in a criminal case, and Camacho’s earlier proceeding challenged the legality of his sentence in a separate criminal case. The opinion states that Rodriguez was incarcerated at F.C.I. Fort Dix in New Jersey and Camacho was incarcerated at F.C.I. Schuylkill in Pennsylvania.
In 2016, the Federal Defenders of New York were assigned to review their convictions in light of Johnson v. United States. Johnson held that the Armed Career Criminal Act’s definition of “violent felony” was unconstitutionally vague. The Federal Defenders asked to brief whether Johnson applied to the statute involved in these cases. The movants argued that their earlier § 2255 proceedings ended without the court addressing that issue.
The movants also relied on United States v. Davis, which held that the residual clause in 18 U.S.C. § 924(c)(3)(B), defining one category of “crime of violence” for the federal firearms statute, was unconstitutionally vague and that the holding applied retroactively. The opinion states that Davis raised new substantive questions the court needed to address.
Court’s reasoning
The court explained that a post-judgment motion may be treated as a motion under Rule 60(b) of the Federal Rules of Civil Procedure when it concerns the integrity of the prior federal habeas proceeding rather than the integrity of the criminal trial. Because Rodriguez and Camacho appeared not to have had an opportunity to be heard on the Johnson-related claims, the court concluded that their joint application was properly made as a Rule 60(b) motion to reopen the earlier proceedings.
The court did not resolve the Johnson or Davis issues, determine whether either conviction or sentence was legally valid, or grant habeas relief.
Order and effect
Senior United States District Judge C.O. S. Haight, Jr. ordered the Clerk of Court to file the joint application as a Rule 60(b) motion in the consolidated proceedings. The court vacated its prior November 12, 2019 Memorandum and Order and directed the Clerk to administratively close four newly opened civil actions. It also vacated the prior deadline for the United States to respond.
The court directed the Clerk to send the order to Rodriguez and Camacho, notify the Federal Defenders and the United States, and gave the Federal Defenders 14 days to state whether they intended to represent either movant and, if so, propose a briefing schedule. After receiving that response, or after the deadline expired, the court said it would direct the United States to respond. All future filings were ordered to be made in the consolidated proceedings.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.