United States v. Xin

1 Citing case

  1. United States v. Foley

    273 F. Supp. 3d 562 (W.D. Pa. 2017)   Cited 2 times
    Holding that petitioner's second-in-time motion under § 2255, which was based on vacatur of state convictions years after petitioner's federal sentence, "constitute[d] a non-successive § 2255 motion, making the provisions of § 2255(h) inapplicable."

    While the Third Circuit Could of Appeals has not provided a definitive list of situations that would amount to a miscarriage of justice, it has endorsed the view that only extraordinary situations suffice. SeeUnited States v. Phi Xin, 451 Fed.Appx. 115, 118 (3d Cir. 2011) (citing cases); see alsoUnited States v. Wilson , 429 F.3d 455, 458 (3d Cir. 2005) (stating that the "miscarriage of justice" concept is to be applied " ‘sparingly and without undue generosity’ ") (quoting United States v. Teeter , 257 F.3d 14 (1st Cir. 2001) ). The Third Circuit has stated that the reviewing court should evaluate waivers on a case-by-case basis, considering the error claimed by the defendant and such factors as: