Patrick Albert Byers, Jr. is a federal prisoner seeking to challenge his 2009 conviction, which was previously affirmed by the Fourth Circuit in 2011. In 2016, Byers filed a motion in the District Court for the District of Maryland labeled as a 'Motion for Request of Discovery.' The district court treated this filing as a motion for relief under Federal Rule of Civil Procedure 60(b) and denied it. Byers appealed that denial. However, the record shows that the district court had already adjudicated Byers's first § 2255 motion on the merits in September 2015. The core dispute is whether the 2016 motion, despite its label, functioned as a second or successive habeas petition that required prior appellate approval before the district court could hear it.
The Fourth Circuit analyzed the nature of the 2016 motion under the Supreme Court's decision in Gonzalez v. Crosby. The court concluded that because the motion sought to revisit the district court's prior denial of a § 2255 claim on the merits, it was substantively a second or successive § 2255 motion, regardless of the Rule 60(b) label. Under 28 U.S.C. § 2255(h), a prisoner must obtain authorization from the court of appeals before filing such a motion. Because Byers had not obtained this authorization, the district court lacked jurisdiction to consider the motion. The court cited United States v. Winestock to affirm that when a district court lacks jurisdiction, it must dismiss the motion. Additionally, the Fourth Circuit construed Byers's notice of appeal and appellate brief as a formal application for authorization to file the successive petition. Upon review, the court found that Byers's claims failed to satisfy the applicable legal standard for authorization.
The district court's orders denying the 2016 motion are vacated. The case is remanded with specific directions to dismiss the motion for lack of jurisdiction. Furthermore, the Fourth Circuit has denied Byers's application for authorization to file a second or successive § 2255 motion, effectively closing the door on this specific collateral attack unless new grounds arise that meet the strict statutory requirements.