4th Cir.

Luke D. Patterson v. Warden R. Brown

July 21, 2026 ·26-6576 ·Per Curiam ·Per Curiam · By James Taylor

The United States Court of Appeals for the Fourth Circuit affirmed the district court's denial of a federal prisoner's motion for reconsideration regarding a habeas corpus petition.

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Background

Luke Patterson, a federal prisoner representing himself, sought relief under Section twenty eight United States Code, Section two thousand two hundred forty one. The district court denied the petition and subsequently denied Patterson’s motion for reconsideration.

The court’s reasoning

The appellate court reviewed the district court’s denial for abuse of discretion. The court found no abuse of discretion in denying the motion for reconsideration. The court noted that the motion was properly treated under Rule sixty point B because the time limit for Rule fifty-nine E had expired.

What it means going forward

Federal prisoners must adhere to strict deadlines for motions for reconsideration, and appeals from denials of such motions do not reopen the underlying habeas judgment.