Patrick Albert Byers, Jr. v. United States

At petitioner’s federal murder trial in 2009, Baltimore City Police Detective Wayne Jenkins testified against petitioner. A jury convicted petitioner, and the district court sentenced him to life imprisonment. After the district court’s judgment was affirmed on direct appeal in 2011, petitioner moved for post-conviction relief under 28 U.S.C. § 2255, which the district court denied in 2015. Petitioner’s original § 2255 motion did not raise a due process claim that Jenkins had committed perjury at trial. In 2017, Jenkins was charged in federal court with various offenses related to his widespread corruption and violent conduct as a police detective in Baltimore – what the district court in petitioner’s case described as “rampant.” In 2018, Jenkins was convicted and sentenced to a lengthy term of imprisonment. In 2020, a book was published providing detailed information about Jenkins’ rampant corruption and perjury. In 2021, petitioner filed a Rule 60(b) motion, seeking to raise a new claim that Jenkins had committed perjury at petitioner’s trial. The district court, concluding that evidence of Jenkins’ rampant corruption and perjury was not known to petitioner when the court denied § 2255 relief in 2015, granted petitioner relief under Rule 60(b) and permitted petitioner to raise a perjury claim. The district court denied the perjury claim on the merits in 2022 and again, on reconsideration, in 2025. On appeal, citing Gonzalez v. Crosby, 545 U.S. 524 (2005), the Fourth Circuit vacated the district court’s judgment for lack of jurisdiction – concluding that the district court had erred by affording petitioner relief under Rule 60(b) and holding that petitioner’s perjury claim was barred by § 2255(h)’s limitation on second or successive claims. In view of the foregoing, the question presented is: Whether, when a member of the prosecution team concealed material information that would have supported a constitutional claim during the litigation of a defendant’s initial § 2255 motion, a district court may later grant Rule 60(b) relief and permit the defendant to amend his original motion and raise the new claim on the ground that the concealment undermined the integrity of the initial § 2255 proceeding.