Penny v. Brown

CourtDistrict Court, E.D. Michigan
DecidedAugust 12, 2025
Docket2:20-cv-10359
StatusUnknown

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Bluebook
Penny v. Brown, (E.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION JAMES R. PENNY,

Plaintiff, Case No. 20-10359 Honorable Laurie J. Michelson v.

MIKE BROWN,

Defendant.

OPINION AND ORDER DENYING MOTION FOR RECONSIDERATION [11] James R. Penny is serving a life sentence for second-degree murder in connection with the 1992 stabbing death of his girlfriend. He seeks relief from the Court’s 2020 order (ECF No. 5) transferring his 28 U.S.C. § 2254 habeas petition to the Sixth Circuit as a second or successive petition. For the reasons below, the Court DENIES Penny’s motion (ECF No. 11).

In 1996, Penny filed his first habeas corpus petition in this Court. See Penny v. Burke, No. 96-10442 (E.D. Mich. filed Dec. 11, 1996). Judge Robert H. Cleland denied that petition on the merits in 1997. Penny, No. 96-10442, ECF No. 18; see also Penny, No. 96-10442, ECF No. 29 (denying certificate of appealability); Penny v. Burke, No. 97-2213 (6th Cir. June 3, 1998), ECF No. 11 (same). The Sixth Circuit later denied Penny’s 2002, 2003, and 2011 motions to file successive habeas petitions. In re Penny, No. 02-1416 (6th Cir. Nov. 1, 2002), ECF No. 15; In re Penny, No. 03- 1933 (6th Cir. Dec. 1, 2003), ECF No. 7; In re Penny, No. 10-1230 (6th Cir. Jan. 19, 2011), ECF No. 28. In 2020, Penny filed another § 2254 petition (ECF No. 1), which this Court

transferred to the Sixth Circuit pursuant to 28 U.S.C. § 1631 for determination of whether it was a second or successive petition within the meaning of 28 U.S.C. § 2244(b) (ECF No. 5). (See id. at PageID.34–35 (“Penny could have raised his current claims in his previous petition. The earlier habeas petition was dismissed on the merits. Therefore, the current petition is ‘second or successive’ to the 1996 petition and Penny was required to seek preauthorization from the Court of Appeals before filing the petition here, which he did not do.”).) The Sixth Circuit in turn denied

Penny’s motion for authorization to file a second or successive habeas petition, concluding that the petition “d[id] not rely on a new rule of constitutional law” and that Penny’s actual innocence claim was based on facts known to Penny at the time of his trial.1 In re Penny, No. 21-1122 (6th Cir. Aug. 24, 2021), ECF No. 10, PageID.2; see 28 U.S.C. § 2244(b)(2) (providing the bases on which a petitioner may be granted permission to file a second or successive habeas petition).

Penny now seeks relief from the Court’s transfer order on the ground that the Court failed to decide his actual innocence claim. (ECF No. 11.) Although Penny titles the motion “Motion for Reconsideration,” the Court construes it as a motion for relief

1 Penny’s assertion of actual innocence was based on a claim of self-defense. Penny asserted “that the victim attacked him in his home by throwing wine bottles at him, that they fought, and that he stabbed her to death while defending himself.” In re Penny, No. 21-1122 (6th Cir. Aug. 24, 2021), ECF No. 10, PageID.2. from judgment under Federal Rule of Civil Procedure 60(b). Indeed, Penny cites Rule 60(b) throughout. And this Court’s local rules provide that “[p]arties seeking reconsideration of final orders or judgments must file a motion under Federal Rule of

Civil Procedure 59(e) or 60(b),” rather than a motion for reconsideration under Local Rule 7.1(h). E.D. Mich. LR 7.1(h)(1). Penny “must overcome two procedural hurdles: (1) his Rule 60(b) motion must not be a second or successive habeas petition prohibited by AEDPA and (2) he must satisfy the requirements of Rule 60(b).” Mitchell v. Rees, 261 F. App’x 825, 828 (6th Cir. 2008). He fails at the second requirement.

When a habeas petitioner files a Rule 60(b) motion, the “threshold inquiry is whether [the petitioner’s] Rule 60(b) motion is a ‘true’ Rule 60(b) motion or simply a ‘second or successive’ habeas application cloaked in Rule 60(b) garb.” Franklin v. Jenkins, 839 F.3d 465, 473 (6th Cir. 2016) (quoting Gonzalez v. Crosby, 545 U.S. 524, 531 (2005)). This threshold inquiry is necessary because the Court may not adjudicate the merits of a second or successive habeas petition without prior authorization from

the Sixth Circuit. See 28 U.S.C. § 2244(b)(3)(A) (“Before a second or successive application . . . is filed in the district court, the applicant shall move in the appropriate court of appeals for an order authorizing the district court to consider the application.”); Franklin, 839 F.3d at 475 (“[D]istrict courts lack jurisdiction to consider ‘second or successive’ habeas applications without prior authorization from the appropriate Court of Appeals . . . .”). A filing otherwise styled as a Rule 60(b) motion is treated as a successive habeas petition within the meaning of 28 U.S.C. § 2244(b) if it “challenges the same conviction challenged in a prior petition and the prior petition was decided on the

merits.” (ECF No. 5, PageID.34 (citing In re Garner, 612 F.3d 533, 535 (6th Cir. 2010))); Gonzalez, 545 U.S. at 538 (“[A] Rule 60(b)(6) motion in a § 2254 case is not to be treated as a successive habeas petition if it does not assert, or reassert, claims of error in the movant’s state conviction.”). In contrast, a “true” Rule 60(b) motion “attacks, not the substance of the federal court’s resolution of a claim on the merits, but some defect in the integrity of the federal habeas proceedings.” Gonzalez, 545 U.S. at 532; see Mitchell, 261 F. App’x at 829 (explaining that a movant has filed a proper

Rule 60(b) motion, rather than successive habeas petition, if he “assert[s] that a previous ruling which precluded a merits determination was in error—for example, a denial [of a habeas petition] for such reasons as failure to exhaust, procedural default, or statute-of-limitations bar”). Put another way, a petitioner has filed a “true” Rule 60(b) motion “[w]hen no ‘claim’ is presented,” and “neither the motion itself nor the federal judgment from which it seeks relief substantively addresses federal

grounds for setting aside the movant’s state conviction.” Gonzalez, 545 U.S. at 533. Penny’s argument that the Court failed to consider his actual innocence claim constitutes a “true” 60(b) claim because it attacks the integrity of the federal habeas proceedings. See Jackson v. Lafler, No. 07-11808, 2013 WL 450935, at *1 (E.D. Mich. Feb. 6, 2013) (“Petitioner’s allegation that this Court failed to consider one or more of his claims would constitute a ‘true’ 60(b) claim that attacks the integrity of the habeas proceedings and would not be considered a successive habeas petition.”); see also Tyler v. Anderson, 749 F.3d 499, 508 (6th Cir. 2014) (assuming without deciding that movant’s argument that the district court failed to consider his habeas claim was a

true Rule 60(b) motion). The motion, therefore, is not subject to the jurisdictional bar of § 2244(b).

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In Re Garner
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Arthur Tyler v. Carl Anderson
749 F.3d 499 (Sixth Circuit, 2014)
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