Case Explained: WILLIAM BRACEY v. SUPERINTENDENT ROCKVIEW SCI; PA ATTORNEY GENERAL; DISTRICT ATTORNEY OF DAUPHIN COUNTY

Court: United States Court of Appeals for the Third Circuit Filed: 2026-06-26 The Third Circuit affirmed the District Court’s order denying William Bracey’s motion under Federal Rule of Civil Procedure 60(b)(6) to reopen his 2011 federal habeas corpus petition challenging his 1995 first-degree murder conviction. The court held that Bracey failed to demonstrate the “extraordinary circumstances” required for relief, applying the six-factor equitable test established in *Cox v. Horn*, 757 F.3d 113 (3d Cir. 2014). While the court found that the intervening change in law from *Dennis v. Secretary, Pa. Dep’t of Corr.* was material to the original dismissal and that Bracey acted diligently in filing his motion, the remaining factors weighed heavily against reopening the case. Specifically, the court determined that Bracey did not show a likelihood of success on the merits because the undisclosed charges against prosecution witnesses were unlikely to have changed the trial’s outcome given the overwhelming evidence of guilt, including multiple eyewitness accounts and forensic testimony. Furthermore, the court found that reopening the judgment would unduly disturb the finality of a conviction over thirteen years old and undermine federal-state comity, and Bracey failed to make a showing of actual innocence required by the fifth factor. Although the District Court erred in its analysis of the first *Cox* factor by requiring the change in law to be “extraordinary” rather than merely “material,” the court applied the harmless error standard under 28 U.S.C. § 2111, concluding that this error did not affect the outcome given the strong weight of the other factors against relief. Consequently, Bracey’s request for habeas relief was denied, and his conviction remains final. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.