Case Explained: UNITED STATES OF AMERICA v. ROBERTO ANTOINE DARDEN

Court: United States Court of Appeals for the Fourth Circuit Filed: 2026-07-28 The fourth-circuit affirmed the district court’s dismissal of Roberto Antoine Darden’s motion to amend his Section 2255 petition, construing it as an unauthorized successive habeas motion over which the district court lacked jurisdiction because Darden failed to obtain prefiling authorization. The court applied 28 U.S.C. §§ 2244(b)(3)(A) and 2255(h), relying on *McRae* and *Bixby v. Stirling* to hold that postjudgment motions seeking to revisit merits denials or present new claims must be treated as successive petitions. Additionally, the court construed Darden’s notice of appeal and informal brief as an application for authorization to file a second or successive § 2255 motion, which it denied because the claims did not meet the statutory standards under § 2255(h). The court also denied Darden’s pro se motion for appointment of counsel. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.