Brown: Magistrate Judges Lack Statutory Authority to Enter Final Judgment in 2255 cases

In Brown v. U.S., Nos. 11-15149 & 12-10293 (April 7, 2014), the Court held that entry of final judgment on a motion to vacate a sentence under 28 U.S.C. § 2255 falls outside the grant of statutory authority to Magistrate Judges delegated in 28 U.S.C. § 636(c). Declining to reach the issue whether Article III of the Constitution prohibits a Magistrate Judge from entering final judgment on a § 2255 motion, the Court analyzed at length the history of the magistrate system and Supreme Court caselaw regarding Magistrate Judge authority. The Court noted that Magistrate Judges are appointed by District Courts, and would not be expected to evaluate the District Courts’ conduct at trial in a § 2255 motion. The Court also noted that it was constitutionally troublesome for Magistrate Judges to exercise a Judicial Power reserved for Article III courts. The Court therefore vacated the Magistrate Judge’s order denying Brown’s § 2255 motion and, expressing no views on the merits of Brown’s underlying claims for § 2255 relief, remanded the case to the District Court for disposition.