Case Explained: JAFARNIA WILLIAMS v. SUPERINTENDENT ROCKVIEW SCI; ATTORNEY GENERAL OF PENNSYLVANIA

Court: United States Court of Appeals for the Third Circuit Filed: 2026-06-15 The Third Circuit affirmed the District Court’s denial of Jafarnia Williams’s motion under Federal Rule of Civil Procedure 60(b) to reopen his previously dismissed federal habeas corpus petition. The court held that a change in case law, specifically the Third Circuit’s decision in *Lesko v. Sec’y, Pa. Dep’t of Corr.*, does not constitute an “extraordinary circumstance” sufficient to warrant relief under Rule 60(b)(6) without accompanying equitable factors. The court applied the stringent standard for Rule 60(b)(6), which requires a movant to demonstrate “extraordinary circumstances where, without such relief, an extreme and unexpected hardship would occur.” The opinion established that while a change in law is a relevant factor, it cannot serve as the sole basis for reopening a final judgment unless the new rule falls within a narrow retroactivity exception. Furthermore, the court clarified that Rule 60(b)(6) cannot be used to circumvent the restrictions on successive habeas petitions or to repackage untimely motions based on legal error. Because Williams failed to allege any facts demonstrating extreme hardship, actual innocence, lack of diligence, or other equitable circumstances in his motion, and because his claims largely recycled previously denied arguments, the court determined that a remand would be futile. As a practical consequence, the denial of the motion to reopen remains in effect, leaving the District Court’s prior dismissal of Williams’s habeas petition as final and barring him from relitigating those claims through this procedural mechanism. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.