Supreme Court of the United States
Kemp v. United States
June 13, 2022596 U.S. 528
Summary
The Supreme Court held, based on the text, structure, and history of Federal Rule of Civil Procedure 60(b), that the term "mistake" in Rule 60(b)(1) includes a judge's errors of law, and it declined the Government's invitation to limit the term to "obvious" legal errors. Because Dexter Kemp's 2018 motion to reopen his 28 U.S.C. § 2255 proceedings alleged that the District Court misapplied controlling law in computing when his judgment of conviction became final, the motion was cognizable under Rule 60(b)(1), subject to Rule 60(c)'s one-year limitations period, and therefore untimely. The Court accordingly affirmed the Eleventh Circuit's judgment.