Satterfield v. District Attorney — habeas corpus — reversal — Vanaskie

The Third Circuit issued an important habeas corpus opinion today that makes it a bit less difficult for prisoners who assert their innocence to get back in court and have their claims heard on the merits.

In 2013, the Supreme Court held that, when habeas petitioners make a strong enough showing of actual innocence, courts will reach the merits of their petitions that otherwise would be dismissed because they were filed too late. The question in today’s case was, what about petitioners who lost before 2013? If they lost on statute-of-limitations grounds then, and they have enough evidence of their innocence, do they get to reopen their case? Or, in habeas-speak, can McQuiggan support a Rule 60(b) motion?

Today, the court ruled in favor of the petitioner, holding that the district court erred when it ruled that 60(b) wasn’t available for petitioners invoking McQuiggan to get relief from a prior ruling that their petition was time-barred. The opinion emphasized that ” The principles underlying the Supreme Court’s decision in McQuiggin are fundamental to our system of government” and important to the 60(b) analysis. Conversely, the opinion observed that finality and comity ” must yield to the fundamental right not to be wrongfully convicted” and thus get ” less weight … when a petitioner asserts a threshold claim of actual innocence.”

Joining Vanaskie were Ambro and Restrepo. Arguing counsel were Aren Adjoian of the EDPA federal defender for the petitioner and Simran Dhillon of the Philadelphia DA for the Commonwealth.