Farrar v. Raemisch

BACHARACH, Circuit Judge.

*1129 Mr. Charles Farrar, a Colorado state prisoner, appeals the district court's denial of his petition for habeas relief. In district court, Mr. Farrar claimed

• actual innocence,

• deprivation of due process based on the recantation of a key prosecution witness, and

• deprivation of due process based on a state appellate decision establishing an overly restrictive standard for a new trial.

The district court denied relief, and we affirm based on three conclusions:

1. Actual innocence does not supply a freestanding basis for habeas relief.

2. A private citizen's false…