QUESTION 1
an extraordinary This Court holds that factual innocence equates to
circumstance that overrides a statute of limitation. McQuiggin v. Perkins, 133
1924 (2013). Nonetheless, the Eleventh Circuit found Mr. Middlebrook's S.Ct.
habeas-related Rule 60(b) motion untimely despite his underlying claim sounding
in actual innocence.
Rule 60(b) motion seeks adjudication of an unanswered actual-
innocence —related claim, can the motion be untimely?When a

QUESTION 2
Federal bank robbery requires the institutional victim to be insured by the
Federal Deposit Insurance Corporation. After more than a decade, the government
released evidence established that the corporate victim was not insured. If the
government had timely released this evidence, then the original § 2255 court
would have addressed two questions: (1) did constitutional error result in the
conviction of an actually innocent person, and (2) did the district court have
subject-matter jurisdiction since the indictment's did not identify a crime?
corroborated claim of actual innocence constitute an extraordinary Does a
circumstance that justifies reopening the habeas proceedings to adjudicate the
unresolved claims?

QUESTION 3
In the Rule 60(b)context,the Eleventh Circuit's standard forgranting a
certificate of appealability conflicts with this Court's holdings. The Eleventh
Circuit implicitly conducts a merits analysis, and denies the COA based on that
Then, the appeals court exacerbates its error by issuing a boilerplate
order that obfuscates its departure from 28 U.S.C. § 2253(c)(2)'s requirements,
137 S. Ct. 759 (2017); Miller-El v.review.
as this Court defines them. Buck v. Davis,
Cockrell, 537 U.S. 322 (2003).
Should the Eleventh Circuit limit its COA analysis to the debatability of
the threshold questions for Rule 60(b) relief?

Does a corroborated claim of actual-innocence constitute an extraordinary-circumstance that justifies reopening the habeas-proceedings to adjudicate the unresolved-claims?