LAW.coLAW.co

UNITED STATES v. RUTHERFORD (2021)

United States Court of Appeals, Fifth Circuit.2021-03-29No. No. 20-40619

Summary

Holding. The appeal was dismissed as frivolous, the in forma pauperis motion was denied, and Rutherford was ordered to pay a $100 sanction and barred from filing further challenges to his conviction in the Fifth Circuit or related courts until the sanction is paid.

Bruce Rutherford, a federal prisoner convicted of child pornography possession, sought to appeal in forma pauperis after his motion challenging the factual basis of his guilty plea was denied. To proceed without paying court costs, he was required to demonstrate financial hardship and raise nonfrivolous legal issues on appeal. The court found that Rutherford failed to meet the second requirement.

The court determined that Rutherford's motion was legally deficient in multiple ways. He attempted to use Federal Rule of Civil Procedure 52, which does not apply to criminal cases. Even if his motion were reframed as a petition under 28 U.S.C. § 2255 (the proper mechanism for challenging a conviction), his challenge could not proceed because he had already raised a similar claim on direct appeal without success. The court noted that any potential amendments to his argument should be pursued through a § 2255 motion already pending in the district court.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Applicability of civil procedure rules to criminal convictions
  • Frivolousness standard for in forma pauperis appeals
  • Proper vehicle for challenging conviction on factual grounds
  • Res judicata bar to successive similar claims on appeal

Procedural posture

Rutherford appealed from the denial of a motion challenging his guilty plea conviction and sought to proceed in forma pauperis.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

Bruce Allen Rutherford, federal prisoner # 27006-078, has moved for leave to proceed in forma pauperis (IFP) on appeal from the denial of his self-styled motion under Federal Rule of Civil Procedure 52 in which he contested the factual basis supporting his guilty plea conviction for possession of child pornography. To appeal IFP, Rutherford must make the necessary economic showing and assert nonfrivolous issues on appeal. See Carson v. Polley, 689 F.2d 562, 586 (5th Cir. 1982); see also Baugh v. Taylor, 117 F.3d 197, 202 (5th Cir. 1997); Fed. R. App. P. 24(a).

Regardless of whether he is able to afford the costs of litigation without undue hardship or deprivation of lifes necessities, see Adkins v. E.I. DuPont de Nemours & Co., 335 U.S. 331, 339, 69 S.Ct. 85, 93 L.Ed. 43 (1948), Rutherford has not raised a claim that is arguable on the merits, see Howard v. King, 707 F.2d 215, 220-21 (5th Cir. 1983). He effectively seeks to appeal from a motion that is unauthorized or meaningless or that does not permit him to obtain the relief that he seeks. See, e.g., United States v. Early, 27 F.3d 140, 142 (5th Cir. 1994). Federal Rule of Civil Procedure 52 does not apply to criminal matters, see Fed. R. Civ. P. 1; Fed. R. Civ. P. 52, and Federal Rule of Criminal Procedure 52, which does apply, is inapposite and does not provide a basis for Rutherford to attack collaterally his conviction, see Fed. R. Crim. P. 52; United States v. Frady, 456 U.S. 152, 163, 102 S.Ct. 1584, 71 L.Ed.2d 816 (1982). If the motion was treated as a 28 U.S.C. § 2255 motion, his challenge to the factual basis would not be cognizable because he unsuccessfully raised a similar claim on appeal. See United States v. Kalish, 780 F.2d 506, 508 (5th Cir. 1986). Because he has a § 2255 motion pending in the district court, any possible amendment or filing implicating that motion should be presented in connection with that ongoing proceeding. See Fed. R. Civ. P. 15(a)(1), (2). Rutherford otherwise has not shown that he has a nonfrivolous challenge to the disposition of his motion. See Howard, 707 F.2d at 220-21.

Accordingly, the appeal is DISMISSED as frivolous. See Baugh, 117 F.3d at 202 n.24; Howard, 707 F.2d at 220-21; see also 5th Cir. R. 42.2. The IFP motion is DENIED. See id. Rutherford is ORDERED to pay a sanction of $100 to the clerk of this court, and he is BARRED from filing in this court or any court subject to this courts jurisdiction a challenge to his conviction and sentence until the sanction is paid, unless he obtains leave of the court in which he seeks to file such challenge. Rutherford is once again WARNED that any repetitive or frivolous filings in this court or any court subject to this courts jurisdiction will invite the imposition of further sanctions, including dismissal, monetary sanctions, and restrictions on his ability to file pleadings in this court and any court subject to this courts jurisdiction.

FOOTNOTES

FOOTNOTE

Per Curiam:*

FN* Pursuant to 5th Circuit Rule 47.5, the court has determined that this opinion should not be published and is not precedent except under the limited circumstances set forth in 5th Circuit Rule 47.5.4.