Background
LeAnthony T. Winston filed a motion under 28 U.S.C. Section 2255 seeking relief from his federal conviction. The district court denied relief on the merits and subsequently denied a motion for reconsideration. Winston attempted to appeal these orders without first obtaining a certificate of appealability.
The court’s reasoning
The court explained that orders denying Section 2255 relief 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 Winston had not made the requisite showing.
What it means going forward
The dismissal prevents the appellate court from reviewing the merits of the prisoner’s constitutional claims, leaving the district court’s denial of relief in place.