Background
Federal prisoner Luke D. Patterson filed a petition for habeas relief under 28 U.S.C. § 2241. The U.S. District Court for the Northern District of West Virginia adopted a magistrate judge’s recommendation and denied the petition on February 13, 2026.
Patterson subsequently sought reconsideration. Although the district court treated his April 8, 2026 motion as timely under Federal Rule of Civil Procedure 59(e), the Fourth Circuit explained that a court cannot extend Rule 59(e)’s 28-day filing period. Because Patterson filed the motion more than 28 days after judgment, it had to be treated as a Rule 60(b) motion.
The Court’s Holding
In an unpublished per curiam opinion, the Fourth Circuit affirmed the denial of Patterson’s Rule 60(b) motion. Applying abuse-of-discretion review, the court concluded after reviewing the record that the district court did not abuse its discretion in refusing reconsideration.
The court did not review the merits of the original order denying Patterson’s § 2241 petition. It emphasized that an appeal from the denial of a Rule 60(b) motion does not bring the underlying judgment before the appellate court for review. The panel also dispensed with oral argument.
Key Takeaways
- A reconsideration motion filed more than 28 days after judgment cannot qualify as a timely Rule 59(e) motion and must instead be evaluated under Rule 60(b).
- A district court lacks authority to extend Rule 59(e)’s filing deadline.
- An appeal from the denial of Rule 60(b) relief permits review of that denial for abuse of discretion, not review of the underlying judgment.
Why It Matters
The decision underscores the procedural consequences of missing Rule 59(e)’s strict deadline. Characterization of a reconsideration motion affects both the governing standard and the scope of appellate review.
For habeas litigants, appealing only the denial of an untimely reconsideration motion does not provide a route to appellate review of the original judgment denying relief.