Background
Octavious Artis filed a motion under 28 United States Code Section 2255 seeking relief from his conviction and sentence. The district court denied relief on his motion and also denied his motion to alter or amend the judgment. Artis sought to appeal these orders from the United States District Court for the Eastern District of North Carolina.
The court’s reasoning
The court explained that orders denying relief on a Section 2255 motion are not appealable unless a circuit justice or judge issues a certificate of appealability. To obtain such a certificate, a prisoner must make a substantial showing of the denial of a constitutional right. When relief is denied on the merits, the prisoner must show that reasonable jurists could find the district court’s assessment debatable or wrong. The court independently reviewed the record and concluded that Artis had not made the requisite showing.
What it means going forward
The dismissal prevents the appellate court from reviewing the merits of Artis’s constitutional claims, leaving the district court’s denial of his habeas motion in place.