Batton v. United States

CourtDistrict Court, E.D. Wisconsin
DecidedJuly 8, 2020
Docket2:20-cv-00173
StatusUnknown

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

Bluebook
Batton v. United States, (E.D. Wis. 2020).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN

DEON R. BATTON,

Petitioner, Case No. 20-cv-173-pp v.

UNITED STATES OF AMERICA

Respondent.

ORDER DENYING MOTION TO VACATE, CORRECT OR SET ASIDE SENTENCE UNDER 28 U.S.C. §2255 (DKT. NO. 1), DISMISSING CASE, AND DECLINING TO ISSUE A CERTIFICATE OF APPEALBILITY

I. Background In November 2017, a grand jury returned an indictment charging the petitioner—along with co-defendant Laura Walton—with five counts of Hobbs Act Robbery under 18 U.S.C. §§1951(a) and 2 and five counts of using a firearm during a crime of violence under 18 U.S.C. §924(c)(1)(A)(ii) and 2. United States v. Deon Batton, Case No. 17-cr-187, Dkt. No. 11 (E.D. Wis. Nov. 17, 2017). The petitioner signed a plea agreement, id. at dkt. no. 25, and on April 23, 2018, this court accepted his guilty plea on five counts of Hobbs Act robbery as well as one count of using and carrying a firearm during a crime of violence. Id. at Dkt. No. 26. On February 1, 2019, the court sentenced the petitioner to thirty months’ imprisonment on each of the five Hobbs Act robberies (to run concurrently with each other) and 120 months’ imprisonment on the §924(c) count to run consecutively to the thirty months on the robberies, for a total sentence of 150 months’ imprisonment. Id. at Dkt. No. 59. The court entered judgment on February 4, 2019, id., and an amended judgment on February 6, 2019. Id. at dkt. no. 61. The court later reduced the petitioner’s sentence to a total of 120 months imprisonment. Id. at Dkt. No. 70.

The petitioner did not appeal his conviction or his sentences. On February 4, 2020, the petitioner filed this motion to vacate his sentence under 28 U.S.C. §2255. Batton v. United States, Case No. 20-cv-173, Dkt. No. 1 (E.D. Wis. Feb. 4, 2020). The motion argued that under United States v. Davis, ___ U.S. ___, 139 S. Ct. 2319 (2019), Hobbs Act Robbery cannot be a “crime of violence” under the residual clause of §924(c) and that previous Seventh Circuit precedent erred in concluding that Hobbs Act robbery qualified as a “crime of violence” under the elements clause of §924(c). Dkt. No.

1 at 7. The motion also argues that the petitioner’s trial counsel was ineffective for failing to challenge a defective indictment; the petitioner says the indictment charged him with interfering in “intrastate commerce” and did not plead an interstate commerce element. Id. II. Analysis The first thing a court must do in a proceeding under §2255 is review—or “screen”—the motion. Rule 4 of the Rules Governing Section 2255 proceedings provides that [i]f it plainly appears from the motion, any attached exhibits, and the record of prior proceedings that the moving party is not entitled to relief, the judge must dismiss the motion and direct the clerk to notify the moving party. If the motion is not dismissed, the judge must order the United States attorney to file an answer, motion, or other response within a fixed time, or to take other action the judge may order.

Rule 4(b), Rules Governing §2255 Proceedings. A petitioner seeking relief under §2255 must allege either that the sentence violated the Constitution or laws of the United States, that the court was without jurisdiction, that the sentence exceeded the maximum authorized by law or that the sentence is otherwise subject to collateral attack. 28 U.S.C. §2255(a). At the screening stage, the court considers only whether the petitioner has raised claims that can be adjudicated in a section §2255 proceeding, whether the petitioner has exhausted his claims and whether he filed the motion within the limitations period. The petitioner’s claims appear to be timely filed; it appears the petitioner filed his §2255 motion within one year of his judgment becoming final under 28 U.S.C. §2255(f)(1). A. United States v. Davis Claim The petitioner’s Davis claim has no merit because the Seventh Circuit

Court of Appeals repeatedly has rejected the argument that the petitioner advances. The petitioner argues that the court must vacate his conviction for carrying a firearm during a crime of violence because Hobbs Act robbery does not qualify as a “crime of violence” post-Davis. Dkt. No. 1 at 7. The statute at issue here, 18 U.S.C. §924(c), is the same statute considered by the Davis court. It “authorizes heightened criminal penalties for using or carrying a firearm ‘during and in relation to,’ or possessing a firearm ‘in furtherance of’ any federal ‘crime of violence or drug trafficking crime.’” Davis, 139 S. Ct. at 2324. The statute defines “crime of violence” in “two subparts—the first known as the elements clause, and the second [known as] the residual clause.” Id. Under §924(c)(3), a “crime of violence” is an “offense that is a felony and— (A) has as an element the use, attempted use, or threatened use of physical force against the person or property of another, or

(B) that by its nature, involves a substantial risk that physical force against the person or property of another may be used in the course of committing the offense.

18 U.S.C. §924(c)(3). Davis analyzed subsection (B)—the residual clause—and found it unconstitutionally vague. Id. at 2336. But the Davis decision had no impact on subpart (A)—the elements clause. Haynes v. United States, 936 F.3d 683, 688 (7th Cir. 2019). The petitioner is correct that Davis precludes Hobbs Act robbery from qualifying as a “crime of violence” under the residual clause, 18 U.S.C. §924(c)(3)(B). But the petitioner’s conviction for carrying a firearm during a crime of violence under 18 U.S.C. §924(c) passes constitutional muster if Hobbs Act robbery qualifies as a “crime of violence” under the elements clause, subparagraph (A). The petitioner acknowledges that Hobbs Act robbery currently qualifies as a crime of violence under the elements clause; he argues that previous Seventh Circuit cases “are erroneously based on a misapplication of the categorial approach.” Dkt. No. 1 at 6. The petitioner argues that Hobbs Act robbery covers more conduct than what is listed in the in the elements clause of §924(c)(3)(A) because Hobbs Act robbery can be committed without force. Id. at 24. The Seventh Circuit repeatedly has rejected the arguments made by the petitioner and repeatedly has held that Hobbs Act robbery is a crime of violence under the elements clause of §924(c). See United States v. Rivera, 847 F.3d 847, 849 (7th Cir. 2017) (“[O]ne cannot commit Hobbs Act robbery without

using or threatening force. . . . Because each of the means by which to satisfy the “against his will” element requires physical force, the “against his will element itself requires physical force.”); United States v.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Nelson v. Adams USA, Inc.
529 U.S. 460 (Supreme Court, 2000)
Massaro v. United States
538 U.S. 500 (Supreme Court, 2003)
United States v. Michael Anglin
846 F.3d 954 (Seventh Circuit, 2017)
United States v. Robert Fox
878 F.3d 574 (Seventh Circuit, 2017)
Rodney Washington v. Gary Boughton
884 F.3d 692 (Seventh Circuit, 2018)
United States v. Davis
588 U.S. 445 (Supreme Court, 2019)
United States v. Stacy Haynes
936 F.3d 683 (Seventh Circuit, 2019)
United States v. Rivera
847 F.3d 847 (Seventh Circuit, 2017)

Cite This Page — Counsel Stack

Bluebook (online)
Batton v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/batton-v-united-states-wied-2020.