Equitable Tolling Not Available for 1-Year Time Limit Under Rule 60(b)

US v. Williams: In 2004, Williams was convicted on multiple counts related to drug trafficking and was sentence to life (plus 30 years) in prison. In 2008, he filed a 2255 motion challenging his convictions, which was denied in 2012. In 2016, he filed a motion under Rule 60(b)(3) of the Rules of Civil Procedure arguing that the Government had misrepresented several things during his 2255 proceedings and “prevented him from fully and fairly presenting his case.” The district court ultimately denied the motion, concluding that it was outside the 1-year time limit, that Williams was not entitled to equitable tolling, and that his motion argument failed on the merits.

On appeal, the Fourth Circuit affirmed the denial of Williams’ Rule 60(b) motion. The court ultimately decided it could not resolve whether the 1-year time limited had been equitably told or the merits of Williams’ arguments because, the court concluded, equitable tolling is not applicable to Rule 60(b) motions. While the 1-year time limit was not jurisdictional, it was a mandatory claim processing rule and the court therefore was left “without discretion to extent Rule 60(b)’s one-year time limit for equitable reasons, whatever their merit.”