Kemp v. United States

DeAngelo M. Kemp was convicted on federal drug and firearm charges. Following the Supreme Court's 2019 decision in Rehaif v. United States, which altered the mens rea requirement for certain firearm offenses, Kemp sought to vacate his conviction by filing a motion under Rule 60(b)(6) of the Federal Rules of Civil Procedure, arguing a legal error in his judgment. The district court denied the motion, and the Eleventh Circuit affirmed. The Supreme Court granted certiorari to resolve a circuit split on whether Rule 60(b)(6) motions in criminal habeas contexts are governed by a one-year limitations period. The case centered on whether Kemp's motion, filed over one year after the Rehaif decision, satisfied Rule 60(b)(6)'s requirement that relief be sought within a reasonable time.

The Supreme Court ruled 8-1 in favor of the United States. Justice Clarence Thomas delivered the majority opinion, holding that Kemp's Rule 60(b)(6) motion was not filed within a reasonable time. The Court concluded that a delay of over one year after the Rehaif decision did not constitute a reasonable time, and the motion was therefore properly denied. Justice Sonia Sotomayor filed a dissenting opinion.

Whether a federal prisoner's motion under Rule 60(b)(6) of the Federal Rules of Civil Procedure, seeking relief from a final criminal judgment based on a change in substantive law, must be brought within the one-year limitations period applicable to federal habeas corpus petitions, and whether Kemp's motion was filed within a reasonable time as required by the rule.

The decision clarified the procedural boundaries for federal prisoners seeking post-conviction relief based on subsequent changes in law. It reinforced strict time limitations on Rule 60(b) motions in criminal contexts, preventing defendants from circumventing the Antiterrorism and Effective Death Penalty Act's one-year statute of limitations for habeas corpus petitions. The ruling limited the ability of prisoners to challenge final convictions long after they become final, promoting finality in criminal judgments while underscoring the importance of procedural diligence.