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Sherman Lynch, a Utah inmate, appealed the district court’s denial of his Federal Rule of Civil Procedure 60(b)(1) motion for relief from judgment.
In August 2020, Lynch filed an initial pleading entitled “Petition for Redress Against Utah Attorney General Sean D. Reyes … Under the Fourteenth Amendment.” In it, Lynch alleged Reyes violated his constitutional rights by lying throughout Lynch’s criminal and habeas proceedings.
In November 2021, the district court construed Lynch’s “Petition for Redress” as a civil-rights complaint under 42 U.S. Code 1983. The district court dismissed the complaint with prejudice, reasoning Lynch’s civil rights claims were barred by Supreme Court precedent. The district court concluded Lynch’s allegations didn’t adequately link Reyes to any alleged civil-rights violation and Reyes’ alleged acts during court proceedings were covered by prosecutorial immunity, the opinion noted.
The court also determined Lynch improperly requested habeas relief and instructed any habeas claims must be made in a separate habeas petition. The court noted “neither liberal interpretation of [Mr. Lynch]’s claims nor opportunity to amend would lead to a different result.” Lynch didn’t timely appeal.
In October 2022, Lynch moved for relief from judgment under Rule 60(b)(1) and requested leave to amend his complaint. He argued the district court made several mistakes in its November 2021 order dismissing his complaint. The district court denied the motion and Lynch timely appealed.
Lynch asserted in his motion the district court made several mistakes in its November 2021 order dismissing his complaint. In support, he argued the court improperly construed his 14th Amendment petition as a Section 1983 action, because he didn’t file his claims under Section 1983; misinterpreted his petition as an attack on his underlying conviction, as he never requested to have his conviction invalidated; mistook his petition for a second habeas petition when he wasn’t requesting habeas relief; incorrectly determined he didn’t adequately link Reyes to any alleged civil rights violation, because Reyes was the presiding attorney in his habeas proceedings; and mistakenly afforded Reyes prosecutorial immunity because Reyes wasn’t involved in his criminal proceedings.
The district court determined Lynch wasn’t entitled to relief under Rule 60(b)(1) and denied the motion. The district court first explained it construed Lynch’s claims under Section 1983 because they “were most closely aligned” with a “federal civil-rights action” under that provision. Next, the court said it notified Lynch “that he could not seek habeas relief in a civil-rights case” because his petition noted he sought “to protect his statutory right to a writ of habeas corpus.”
The court further explained under Section 1983 because Reyes was in a supervisory role and didn’t personally participate, he couldn’t be affirmatively linked to the alleged constitutional violations. The court also rejected Lynch’s prosecutorial immunity argument, noting his “claims alleged [Mr. Reyes’] unconstitutional behavior in pursuing and preserving [his] criminal conviction” and concluding “[t]hese acts inherently involved advocacy in legal proceedings.” The court denied Lynch’s motion to amend his initial pleading because his supporting argument repeated arguments the court had previously rejected.
Lynch asserted the district court abused its discretion when it denied his Rule 60(b) motion. The 10th Circuit Court of Appeals explained, “Rule 60(b) relief is extraordinary and may only be granted in exceptional circumstances.” The court’s precedent also established parties seeking relief under Rule 60(b) have a higher hurdle to overcome “because a Rule 60(b) motion is not a substitute for an appeal.” On appeal, Lynch repeated the arguments advanced in his motion. He hadn’t demonstrated the district court abused its discretion in denying his Rule 60(b) motion.
The 10th Circuit panel in Salt Lake City, Utah, affirmed the district court’s judgment and denied Lynch’s motion to appoint an attorney.