Background
Reginald Antonio Twitty appealed the district court’s orders denying his motion for a new trial under Federal Rule of Criminal Procedure thirty-three and denying reconsideration of that denial. The underlying case originated in the United States District Court for the District of South Carolina.
The court’s reasoning
The court reviewed the denial of the motion for a new trial for abuse of discretion. Federal Rule of Criminal Procedure thirty-three requires that a motion based on newly discovered evidence be filed within three years after the verdict or finding of guilty, or within fourteen days if based on any other reason. The court determined that Twitty’s September two thousand twenty-five motion was untimely because it was filed more than three years after his April two thousand twenty-two guilty plea. Although the district court mistakenly suggested that an untimely motion deprived it of jurisdiction, the appellate court noted that Rule thirty-three is a nonjurisdictional claim-processing rule. The court affirmed the denial because Twitty failed to present circumstances suggesting excusable neglect and did not plausibly proffer any newly discovered evidence.
What it means going forward
The decision reinforces the strict time limits for filing motions for a new trial in the Fourth Circuit and clarifies that untimeliness is a claim-processing rule rather than a jurisdictional bar.
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