Decided: July 14, 2014
The Fourth Circuit affirmed the district court, and held that McQuiggin v. Perkins does not extend to cases in which a movant asserts actual innocence from his sentence, rather than from his crime of conviction.
Appellee was convicted of federal cocaine charges, with a sentence enhancement based on two prior Florida state court convictions, among other things. Appellee’s state convictions were later vacated; he subsequently challenged the federal sentencing enhancements but his motions were denied as untimely. Appellee then appealed to the Fourth Circuit, arguing that, under McQuiggin, he was “actually innocent” of his sentence, and was entitled to equitable relief from the one year statute of limitations. In McQuiggin, the United States Supreme Court, for the first time, provided equitable relief to a statutory bar to prevent the “miscarriage of justice” when an appellee was “actually innocent” of his conviction.
The Fourth Circuit held that that McQuiggin did not extend to actual innocence from sentences. The Court reasoned that because the McQuiggin Court “made no explicit indication that its holding was intended to be applied to the actual innocence of sentence context”, and that “the McQuiggin standard . . . cannot . . . be easily applied to a sentencing decision,” the Appellee was not entitled to equitable relief.