Rivera-Martinez v. United States

How later courts describe this case

• "[p]ermitting the late filing of such a certificate falls within the discretion of the court"
• “Where there are two permissible views of the evidence, the fact-finder’s choice between them cannot be clearly erroneous.”
• “issues, once decided, should not be reopened 'unless the evidence on a subsequent trial was substantially different, controlling authority has since made a contrary decision of the law applicable to such issues, or the decision was clearly erroneous and would work a manifest injustice' ”