Travis Watson v. Detective Altizer

Opinion

USCA4 Appeal: 25-6693 Doc: 12 Filed: 12/31/2025 Pg: 1 of 4

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 25-6691

TRAVIS L. WATSON,

Petitioner - Appellant,

v.

DENNIS DANIELS,

Respondent - Appellee.

No. 25-6692

TRAVIS L. WATSON,

Petitioner - Appellant,

v.

MARK CARVER,

Respondent - Appellee.

No. 25-6693

TRAVIS L. WATSON,

Petitioner - Appellant, USCA4 Appeal: 25-6693 Doc: 12 Filed: 12/31/2025 Pg: 2 of 4

v.

DETECTIVE ALTIZER,

Defendant - Appellee.

Appeals from the United States District Court for the Middle District of North Carolina, at Greensboro. Loretta C. Biggs, Senior District Judge. (1:19-cv-00249-LCB-LPA; 1:17-cv- 01067-LCB-LPA; 1:17-cv-00934-LCB-LPA)

Submitted: December 23, 2025 Decided: December 31, 2025

Before WILKINSON and RUSHING, Circuit Judges, and FLOYD, Senior Circuit Judge.

Nos. 25-6691 and 6692, dismissed; No. 25-6693, affirmed by unpublished per curiam opinion.

Travis L. Watson, Appellant Pro Se.

Unpublished opinions are not binding precedent in this circuit.

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PER CURIAM:

In these consolidated appeals, Travis L. Watson challenges the district court’s order

accepting the magistrate judge’s recommendation, denying his four Fed. R. Civ. P. 60(b)

motions, and ordering him to show cause as to why he should not be enjoined from making

further, similar filings. Watson’s Rule 60(b) motions sought relief from the district court’s

2018 order dismissing his 28 U.S.C. § 2241 petition, its 2020 order denying his 28 U.S.C.

§ 2254 petition, its 2022 judgment in his 42 U.S.C. § 1983 action, and its 2024 order

denying his motion for relief from the 2022 judgment. As a preliminary matter, we grant

Watson’s motion to exceed the length limitations for informal briefs filed in No. 25-6693.

Watson may not appeal the district court’s denial of his Rule 60(b) motions as to its

orders on the § 2241 and § 2254 petitions unless a circuit justice or judge issues a certificate

of appealability. See 28 U.S.C. § 2253(c)(1)(A). A certificate of appealability will not

issue absent “a substantial showing of the denial of a constitutional right.” 28 U.S.C.

§ 2253(c)(2). When the district court denies relief on the merits, a prisoner satisfies this

standard by demonstrating that reasonable jurists could find the district court’s assessment

of the constitutional claims debatable or wrong. See Buck v. Davis, 580 U.S. 100, 115-17

(2017). When the district court denies relief on procedural grounds, the prisoner must

demonstrate both that the dispositive procedural ruling is debatable and that the petition

states a debatable claim of the denial of a constitutional right. Gonzalez v. Thaler, 565 U.S.

134, 140-41 (2012) (citing Slack v. McDaniel, 529 U.S. 473, 484 (2000)).

We have independently reviewed the record and conclude that Watson has not made

the requisite showing as to the district court’s denial of his Rule 60(b) motion challenging

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the dismissal of his § 2241 petition. As to his Rule 60(b) motion challenging the denial of

§ 2254 relief, the claims Watson raised challenged the validity of his convictions and state

sentence, and, thus, the motion should have been construed as a successive § 2254 petition.

See Gonzalez v. Crosby, 545 U.S. 524, 531-32 (2005); United States v. McRae, 793 F.3d

392, 397-99 (4th Cir. 2015). Absent prefiling authorization from this court, the district

court lacked jurisdiction to entertain Watson’s successive § 2254 petition. See 28 U.S.C.

§ 2244(b)(3).

With respect to the district court’s denial of Watson’s Rule 60(b) motions regarding

the § 1983 proceedings and its order that Watson show cause as to why a prefiling

injunction should not issue, we discern no reversible error. Accordingly, we deny a

certificate of appealability and dismiss appeal Nos. 25-6691 and 25-6692, in which Watson

seeks to appeal the denials of his Rule 60(b) motions as to his § 2254 and § 2241 petitions,

respectively. We affirm the district court’s order as to appeal No. 25-6693. We dispense

with oral argument because the facts and legal contentions are adequately presented in the

materials before this court and argument would not aid the decisional process.

Nos. 25-6691 and 25-6692, DISMISSED; No. 25-6693, AFFIRMED