Patton v. United States

Issue: (1) Whether a district court has the authority to reconsider the merits of a 28 U.S.C. § 2255 action in response to a prisoner"s timely post-judgment motion under Federal Rule of Civil Procedure 59(e); and (2) whether, assuming that a prisoner"s notice of appeal would otherwise be timely under Federal Rule of Appellate Procedure 4(a)(4)(A), the court of appeals"s subsequent decision that the post-judgment motion was, in substance, a successive "claim" for relief renders the appeal of the original judgment untimely and deprives that court of jurisdiction over the appeal.