Autrey v. United States

CourtDistrict Court, W.D. Michigan
DecidedSeptember 16, 2024
Docket1:22-cv-00135
StatusUnknown

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

Bluebook
Autrey v. United States, (W.D. Mich. 2024).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION ______

JORDAN AUTREY,

Defendant-Movant, Case No. 1:22-cv-135

v. Honorable Paul L. Maloney

UNITED STATES OF AMERICA,

Plaintiff-Respondent. ____________________________/

OPINION AND ORDER Currently pending before the Court is Defendant-Movant Jordan Autrey (“Defendant”)’s pro se motion to vacate, set aside, or correct his sentence pursuant to 28 U.S.C. § 2255. (ECF No. 1.) For the reasons set forth below, Defendant’s motion will be denied. I. Background On February 24, 2021, a grand jury returned an Indictment charging Defendant with being a felon in possession of a firearm, in violation of 18 U.S.C. § 922(g)(1). See Indictment, United States v. Autrey, No. 1:21-cr-38 (W.D. Mich.) (ECF No. 1). Defendant subsequently entered into a plea agreement in which Defendant agreed to plead guilty to the one-count Indictment. See Am. Plea Agreement, id. (ECF No. 24). Defendant appeared before Magistrate Judge Phillip J. Green on May 14, 2021, for his change of plea hearing. Magistrate Judge Green entered a Report and Recommendation recommending that Defendant’s guilty plea be accepted, and the Court adopted the Report and Recommendation in an order entered on June 2, 2021. See R&R and Order, id. (ECF Nos. 27, 30). The parties appeared before the undersigned for Defendant’s sentencing on August 16, 2021. The Court sentenced Defendant to 71 months’ incarceration, to be followed by 3 years of supervised release. See J., id. (ECF No. 46). Defendant did not appeal his conviction and sentence to the United States Court of Appeals for the Sixth Circuit. Defendant filed his § 2255 motion (ECF No. 1) on February 15, 2022. In an order (ECF

No. 3) entered on February 165, 2022, the Court ordered the government to file a response to the motion. After receiving an extension of time to do so (ECF Nos. 5, 7), the government filed its response (ECF No. 11) on May 25, 2022. Attorney Kenneth P. Tableman, who represented Defendant in his criminal proceeding, filed an affidavit (ECF No. 8) on February 25, 2022. After receiving an extension of time (ECF Nos. 13, 14), Defendant filed his reply (ECF No. 15) on September 6, 2022. II. Analysis A. Legal Standards 1. Section 2255 Proceedings in General A federal prisoner may challenge his sentence by filing in the district court where he was sentenced a motion under 28 U.S.C. § 2255. A valid § 2255 motion requires a movant to show that

“the sentence was imposed in violation of the Constitution or laws of the United States, the court was without jurisdiction to impose such sentence, or that the sentence was in excess of the maximum authorized by law or is otherwise subject to collateral attack.” 28 U.S.C. § 2255(a). Section 2255 affords relief for a claimed constitutional error only when the error had a substantial and injurious effect or influence on the proceedings. Watson v. United States, 165 F.3d 486, 488 (6th Cir. 1999). Non-constitutional errors generally are outside the scope of § 2255 relief, and they should afford collateral relief only when they create a “fundamental defect which inherently results in a complete miscarriage of justice, or, an error so egregious that it amounts to a violation of due process.” Id. (internal quotation marks omitted). As a general rule, a claim not raised on direct review is procedurally defaulted and may not be raised on collateral review absent a showing of either (1) cause and actual prejudice; or (2) actual innocence. Massaro v. United States, 538 U.S. 500, 504 (2003); Bousley v. United States, 523 U.S. 614, 621–22 (1998); United States v. Frady, 456 U.S. 152, 167–68 (1982). A motion to vacate under § 2255 is not a substitute for direct appeal.

United States v. Duhart, 511 F.2d 7 (6th Cir. 1975); DiPiazza v. United States, 471 F.2d 719 (6th Cir. 1973). 2. Evidentiary Hearing The Court must hold an evidentiary hearing to determine the issues and make findings of fact and conclusions of law “[u]nless the motion and the files and records of the case conclusively show that the prisoner is entitled to no relief.” 28 U.S.C. § 2255(b). No hearing is required if Defendant’s allegations “cannot be accepted as true because they are contradicted by the record, inherently incredible, or conclusions rather than statements of fact.” Arredondo v. United States, 178 F.3d 778, 782 (6th Cir. 1999) (quotation omitted). B. Discussion Defendant raises the following grounds for relief in his § 2255 motion:

I. My guidelines were miscalculated. I was enhanced on a prior crime of violence that isn’t necessarily considered violent which my lawyer never looked into when he was asked to do so. II. My criminal history category was increased from a prior misdemeanor from over 10 years. My criminal history was increased from a prior charge that I [completed the Holmes Youthful Trainee Act (HYTA)] on which states no judgment of conviction is entered. (§ 2255 Mot., ECF No. 1, PageID.4–5.) The government contends that: (1) Defendant waived his right to collaterally attack his sentence as part of his guilty plea; (2) his motion raises issues that should have been raised on direct appeal; and (3) Defendant fails to demonstrate any deficiency in counsel’s performance. (ECF No. 11.) 1. Waiver of Right to Attack Sentence The government first contends that Defendant’s grounds for relief are not properly before the Court because Defendant waived his right to collaterally attack his sentence as part of his plea

agreement. (ECF No. 11, PageID.45–46.) The government’s assertion, therefore, implicates the validity of Defendant’s guilty plea. To determine whether a guilty plea is valid, the Court must consider “whether the plea represents a voluntary and intelligent choice among the alternative courses of action open to the defendant.” Hill v. Lockhart, 474 U.S. 52, 56 (1985) (quoting North Carolina v. Alford, 400 U.S. 25, 31 (1970)). A constitutionally valid guilty plea must meet several requirements. First, the defendant must be competent to plead guilty. See Brady v. United States, 397 U.S. 742, 756 (1970). “[T]he standard for competence to stand trial is whether the defendant has ‘sufficient present ability to consult with his lawyer with a reasonable degree of rational understanding’ and has ‘a rational as well as factual understanding of the proceedings against h[er].’” Godinez v. Moran, 509

U.S. 389, 396 (1993) (quoting Dusky v. United States, 362 U.S. 402, 402 (1960) (per curiam)). The defendant must also have notice of the nature of the charges against him. See Henderson v. Morgan,

Related

Dusky v. United States
362 U.S. 402 (Supreme Court, 1960)
MacHibroda v. United States
368 U.S. 487 (Supreme Court, 1962)
Coppedge v. United States
369 U.S. 438 (Supreme Court, 1962)
Brady v. United States
397 U.S. 742 (Supreme Court, 1970)
McMann v. Richardson
397 U.S. 759 (Supreme Court, 1970)
North Carolina v. Alford
400 U.S. 25 (Supreme Court, 1970)
Tollett v. Henderson
411 U.S. 258 (Supreme Court, 1973)
Henderson v. Morgan
426 U.S. 637 (Supreme Court, 1976)
United States v. Frady
456 U.S. 152 (Supreme Court, 1982)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Hill v. Lockhart
474 U.S. 52 (Supreme Court, 1985)
Godinez v. Moran
509 U.S. 389 (Supreme Court, 1993)
Bousley v. United States
523 U.S. 614 (Supreme Court, 1998)
Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
Miller-El v. Cockrell
537 U.S. 322 (Supreme Court, 2003)
Massaro v. United States
538 U.S. 500 (Supreme Court, 2003)
Sam Dipiazza v. United States
471 F.2d 719 (Sixth Circuit, 1973)
David Wayne Baker v. United States
781 F.2d 85 (Sixth Circuit, 1986)

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Bluebook (online)
Autrey v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/autrey-v-united-states-miwd-2024.