Michael James Carson, a Texas state prisoner, sought relief from a 2024 district court judgment that had denied his initial 28 U.S.C. § 2254 habeas corpus application. Carson filed a motion under Federal Rule of Civil Procedure 60(b) asking the district court to set aside that judgment. In his motion, he alleged that the prosecution committed misconduct by suppressing evidence, falsifying evidence, and presenting perjured testimony. He also claimed his trial counsel was ineffective for failing to object to these issues and for failing to object to the suppression of specific evidence. The district court denied the motion, and Carson appealed, seeking a certificate of appealability to challenge that denial.
The Fifth Circuit analyzed whether Carson's Rule 60(b) motion was a proper vehicle for relief or if it functioned as an unauthorized successive habeas petition. Under the Supreme Court's decision in Gonzalez v. Crosby, a Rule 60(b) motion is treated as a successive habeas petition unless it is premised on a defect in the integrity of the prior federal habeas proceedings. The court found that Carson's claims regarding prosecutorial misconduct and ineffective assistance of counsel were either previously raised in his § 2254 proceeding or constituted new § 2254 claims. Because these claims did not allege a defect in the integrity of the prior proceedings, the motion was in substance a successive application for habeas relief. Consequently, the district court lacked jurisdiction to consider the motion because it required prior authorization from the court of appeals under 28 U.S.C. § 2244(b)(3)(A).
The district court's order denying relief is vacated, and the case is remanded with specific instructions to dismiss Carson's Rule 60(b) motion for lack of jurisdiction. This decision reinforces the strict boundary between Rule 60(b) motions and successive habeas petitions, ensuring that prisoners cannot bypass the gatekeeping requirements of the Antiterrorism and Effective Death Penalty Act by framing new claims as procedural errors. The prisoner's request for a certificate of appealability is denied as moot, leaving the underlying state conviction intact.
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