Ahaiwe v. United States

CourtDistrict Court, S.D. New York
DecidedJanuary 23, 2025
Docket1:24-cv-05550
StatusUnknown

This text of Ahaiwe v. United States (Ahaiwe v. United States) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ahaiwe v. United States, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------- X : VICTOR AHAIWE, : 24cv5550 (DLC) : Petitioner, : 20cr179-11 (DLC) : -v- : OPINION AND : ORDER UNITED STATES OF AMERICA, : : Defendant. : : --------------------------------------- X

DENISE COTE, District Judge: On July 19, 2024, Victor Ahaiwe filed a petition for a writ of habeas corpus. For the following reasons, the petition is denied. Background On March 4, 2020, Ahaiwe was charged along with ten co-conspirators in a five-count indictment. Ahaiwe was charged in three counts with participating in a conspiracy to commit bank fraud, participating in a conspiracy to commit money laundering, and the commission of aggravated identify theft, in violation of 18 U.S.C. §§ 1349, 1956(h), and 1028A(a)(1). Ahaiwe was arrested in California on March 8 and released on bail. On August 13, three additional defendants were charged in a superseding indictment. 1 Ahaiwe proceeded to trial. On June 10, 2021, a jury returned a verdict of guilty on each of the three counts for which he had been indicted. As shown at trial, Ahaiwe participated in a far-flung international money laundering scheme to conceal and distribute money obtained by fraud. The evidence at trial included the

movement to the United States of money fraudulently obtained from SZV, a public organization in the island nation of St. Martin that provides health insurance and pension services to the country’s residents. Ahaiwe received $100,000 of the fraud’s proceeds from co-conspirator Herman Bass and laundered that money through six different bank accounts. Five of the accounts were opened in the name of Fatah Paramole, a friend of Ahaiwe who had recently died and whose identify Ahaiwe had assumed. Ahaiwe also stole over $38,000 from Paramole’s estate. The evidence at trial included testimony from an FBI agent who had interviewed Ahaiwe in December 2018. The agent spoke to

Ahaiwe about a series of international wire transactions that appeared to be fraudulent. At the meeting, Ahaiwe signed a money mule letter in which he acknowledged being advised that he may be engaging in money laundering. Only months thereafter, Ahaiwe began opening bank accounts through which he laundered the fraudulently obtained St. Martin funds.

2 The evidence at trial also showed that Ahaiwe had stolen the identities of others. He had possession of a number of fake identification cards, a bank and credit card embossing machine, and a foil stamping machine. On February 11, 2022, Ahaiwe was sentenced principally to a term of 84 months’ imprisonment. Ahaiwe appealed his

conviction, which was affirmed on June 27, 2023. On appeal, Ahaiwe argued that there was insufficient evidence as to venue in the Southern District of New York and that certain evidence regarding identity theft and money laundering was admitted in error at trial. United States v. Ahaiwe, No. 21-2491, 2023 WL 4196954 (2d Cir. June 27, 2023). Ahaiwe did not petition for a writ of certiorari. Therefore, his deadline to file a habeas petition was September 25, 2024. On February 23, 2024, Ahaiwe moved for a reduction of his sentence pursuant to 18 U.S.C. § 3582(c)(2) and for compassionate release. Those motions were denied on July 15.

On April 30 and June 13, Ahaiwe requested copies of documents to assist in the filing of a habeas petition. Ahaiwe’s prior counsel responded to those requests. Ahaiwe filed a timely habeas petition. The petition bears the date June 11, 2024 and was received on July 19. It includes a twenty-four page attachment as well as exhibits. The

3 Government responded on August 12. The petition was fully submitted on October 4 when the defendant’s September 24 reply was docketed.

Discussion Under 28 U.S.C. § 2255, a movant may petition a court to “vacate, set aside or correct” a sentence if “the sentence was imposed in violation of the Constitution or laws of the United States” or is “otherwise subject to collateral attack.” Stone v. United States, 37 F.4th 825, 828 (2d Cir. 2022) (citing 28 U.S.C. § 2255). Pro se litigants are “entitled to a liberal construction of their pleadings, which should be read to raise the strongest arguments that they suggest.” Green v. United States, 260 F.3d 78, 83 (2d Cir. 2001) (citation omitted).

Nevertheless, a pro se habeas petitioner must prove the unconstitutionality of his conviction under § 2255 by a preponderance of the evidence. See Triana v. United States, 205 F.3d 36, 40 (2d Cir. 2000). A procedural default rule prevents claims that could have been brought on direct appeal from being raised on a motion under § 2255 absent a demonstration of either (1) cause and actual prejudice or (2) actual innocence. Gupta v. United States, 913 F.3d 81, 84 (2d Cir. 2019). To demonstrate cause, a defendant must show “some objective factor external to the

4 defense, such that the claim was so novel that its legal basis was not reasonably available to counsel.” Id. (citation omitted). To make a showing of actual innocence, the defendant must prove his “factual innocence, not mere legal insufficiency” by demonstrating that “in light of all the evidence, it is more likely than not that no reasonable juror would have convicted

him.” Id. at 85 (citation omitted). The procedural default rule does not, however, apply to claims of ineffective assistance of counsel. Yick Man Mui v. United States, 614 F.3d 50, 54 (2d Cir. 2010). In support of his petition, Ahaiwe makes various arguments related to his trial, the Government’s actions, his sentencing, and his right to proceed pro se. None of them succeeds in showing that his conviction should be vacated. The majority of Ahaiwe’s claims are barred by the procedural default rule because they were not raised on direct appeal, and Ahaiwe has not shown cause and prejudice or actual innocence. Nonetheless,

the discussion that follows addresses the substance of each of Ahaiwe’s claims. I. Jury Selection Ahaiwe contends that the jury selection process was flawed because the jury was told that he is from Nigeria. He contends that this information biased the jury against him because

5 Nigerians are well known to engage in wire fraud and money laundering. In their voir dire requests, defense counsel asked that the voir dire include the following inquiries: “Mr. Ahaiwe is Nigerian. Do you have any assumptions, opinions, or feelings about Mr. Ahaiwe based on his race or nationality? Does Mr.

Ahaiwe’s race/nationality affect your ability to be fair or impartial to him in any way?” At the final pretrial conference, the Court reviewed the proposed voir dire questions with counsel and inquired whether Ahaiwe was a Nigerian or U.S. citizen. Defense counsel stated that he was a naturalized U.S. citizen. The Court explained that, since Mr.

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