Jafarnia Williams v. Superintendent Rockview SCI; Attorney General of Pennsylvania
June 15, 2026·23-1306·Panel Decision·Bibas·By James Taylor
The Third Circuit affirmed the denial of a motion to reopen a habeas petition under Federal Rule of Civil Procedure sixty point B. The court held that a change in case law alone does not constitute the extraordinary circumstances required to reopen a final judgment.
Jafarnia Williams was convicted in 2007 of kidnapping, corruption of a minor, and drug crimes. He filed multiple habeas petitions and state post-conviction relief petitions over the years. In 2013, he filed a federal habeas petition challenging his sentence, which was dismissed as second or successive. In 2022, he moved to reopen that dismissal under Federal Rule of Civil Procedure sixty point B.
The court’s reasoning
The court reasoned that Rule sixty point B six is a narrow exception to finality requiring extraordinary circumstances and extreme hardship. A change in case law alone, such as the Lesko decision, does not constitute such circumstances without other supporting equitable factors. The petitioner failed to present facts showing hardship, diligence, or actual innocence, making remand futile.
What it means going forward
The decision reinforces that Rule sixty point B six cannot be used to bypass the time limits and finality requirements of habeas corpus proceedings based solely on new legal interpretations.
