Paul Satterfield v. District Attorney Philadelphia

872 F.3d 152
CourtCourt of Appeals for the Third Circuit
DecidedSeptember 26, 2017
Docket15-2190
StatusPublished
Cited by78 cases

This text of 872 F.3d 152 (Paul Satterfield v. District Attorney Philadelphia) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Paul Satterfield v. District Attorney Philadelphia, 872 F.3d 152 (3d Cir. 2017).

Opinion

OPINION OF THE COURT

VANASKIE, Circuit Judge.

Society views the conviction of an innocent person as perhaps the most grievous mistake our judicial system can commit. Reflecting the gravity of such an affront to liberty, the “fundamental miscarriage of justice” exception has evolved to allow ha-beas corpus petitioners to litigate their constitutional claims despite certain procedural bars if the petitioner can make a credible showing of actual innocence. In 2013, the Supreme Court’s decision in McQuiggin v. Perkins, 569 U.S. 383, 133 S.Ct. 1924, 185 L.Ed.2d 1019 (2013), extended this doctrine to allow petitioners who can make this showing to overcome the Antiterrorism and Effective Death Penalty Act’s (“AEDPA”) one-year statute of limitations. 1 In doing so, the Supreme Court recognized that an untimely petition should not prevent a petitioner who can adequately demonstrate his actual innocence from pursuing his claims. This view reflects society’s value judgment that procedure should yield to substance when actual innocence is at stake.

Despite repeatedly asserting his innocence, Appellant Paul Satterfield was convicted of first degree murder in 1985 and sentenced to life in prison. After many years of direct and collateral litigation, he appeared to emerge victorious when the District Court, acting on his habeas petition, found that his ineffective assistance of counsel claim was meritorious. But Satter-field’s hopes for relief were short-lived, as we reversed the .order granting habeas relief after finding that his petition was barred by AEDPA’s statute of limitations. Satterfield’s fight was revived several years later when the Supreme Court handed down its decision in McQuiggin. Had this decision been earlier, Satterfield had more solid support to pursue his ineffective assistance of counsel claim in spite of his untimely petition. In McQuiggin’s wake, Satterfield sought relief from the judgment denying his habeas petition, characterizing McQuiggin’s change in relevant decisional law as an extraordinary circumstance to justify relief under Federal Rule of Civil Procedure 60(b)(6).

The District Court denied Satterfield’s Rule 60(b)(6) motion after determining that McQuiggin was not an extraordinary circumstance. While we do not opine whether the Rule 60(b)(6) motion should ultimately be granted, we will nonetheless vacate the District Court’s order. In Cox v. Horn, 757 F.3d 113 (3d. Cir. 2014), we held that changes in decisional law may—when paired with certain circumstances—-justify Rule 60(b)(6) relief. A district court addressing a Rule 60(b)(6). motion premised on a change in decisional law must examine the full panoply of equitable circumstances in the particular case before rendering a decision. In this case, we believe that the District Court did not articulate the requisite equitable analysis, and we will remand for proper consideration.

Separately, and perhaps more importantly, we explain that the nature of the change in decisional law must be weighed appropriately in the analysis of pertinent equitable factors. McQuiggin implicates the foundational principle of avoiding the conviction of an innocent man and attempts to prevent such a mistake through the fundamental miscarriage of justice exception. If Satterfield can make the required credible showing of actual innocence to avail himself of the fundamental miscarriage of justice exception had McQuiggin been decided when his petition was dismissed, equitable analysis would weigh heavily in favor of deeming McQuig-gin’s change in law, as applied to Satter-field’s case, an exceptional circumstance justifying Rule 60(b)(6) relief. While Sat-terfield’s ability to show actual innocence is not case determinative in that the District Court must weigh all of the equitable factors as guided by precedent, we clarify that the nature of the change in law cannot be divorced from that analysis.

I.

The tortuous path to Satterfield’s current appeal begins more than three decades ago. In 1983, Satterfield visited the home of Azzizah Abdullah to repair her television set. When Satterfield had finished and the television appeared to be working properly, Abdullah paid Satter-field’s fee. But the television ceased working only a short while later, prompting Abdullah to summon Satterfield back to her home to complete the task. He made several additional attempts to fix the recalcitrant television, but his efforts were in vain. During Satterfield’s final service call to Abdullah’s home, her husband William Bryant became frustrated with Satter-field’s repeated failures. Conflict erupted. When Bryant demanded Abdullah’s money back while brandishing a knife and a baseball bat, 2 Satterfield returned the money and quickly departed, never reporting the incident to the police.

Approximately one week after the altercation in Abdullah’s home, Bryant was shot outside his home in the early morning hours. Police interviewed two eyewitnesses—brothers Eric and Grady Freeman—on the morning of Bryant’s murder. The Freemans had been in their home at the time of the shooting and, upon hearing the gunshots, peered out from their windows at the crime scene. Eric Freeman reportedly saw a man who “looked like he was white,” “had like blond hair,” and was about 5’9”. 3 (J.A. 695-97.) According to Eric, the man briskly walked to a parked car, looked both ways before getting in, and had his hand inside his jacket “like he was putting away something.” (J.A. 695-97.) Grady Freeman similarly described seeing a “light skin guy” about 5’7” or 8”. (J.A. 698.) Critically, Satterfield is a black man with brown hair and stands six feet tall. (J.A. 439.)

Investigators soon learned of Satter-field’s recent altercation with Bryant. This information yielded a search warrant for Satterfield’s home and car. Upon execution, however, the searches produced no evidence .implicating Satterfield, and the investigation went dormant for about a year.

The story picks back up in 1984, when Satterfield met Patricia Edwards at a nearby racquet club. Mrs. Edwards suggested that Satterfield play tennis with her husband, Wayne Edwards. After playing together on several occasions, Satterfield and Mr. Edwards met for lunch at the racquet club. The conversation began with benign pleasantries, with the two discussing commonalities in their upbringings, among other things. Mr. Edwards claimed that the conversation eventually culminated with Satterfield admitting to Bryant’s murder in fairly explicit detail. Mr. Edwards contacted the police through his attorney, and Satterfield was arrested days later.

At Satterfield’s trial, Mr. Edwards testified to -'Satterfield’s confession. The State Respondents characterize Mr. Edwards’ testimony on the stand as both credible and corroborated by the evidence. Mr. Edwards told the jury that Satterfield had not reported his altercation with Bryant to the police because he assumed it would be futile based on a past experience with a customer. Mr. Edwards also explained that Satterfield had admitted to disposing of his .44 caliber gun—the purported murder weapon—shortly after the killing, only to later tell police the firearm had been stolen. According to the State Respondents, Mr.

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Bluebook (online)
872 F.3d 152, Counsel Stack Legal Research, https://law.counselstack.com/opinion/paul-satterfield-v-district-attorney-philadelphia-ca3-2017.