Blackwell v. United States

CourtDistrict Court, E.D. Missouri
DecidedJanuary 4, 2024
Docket4:21-cv-00046
StatusUnknown

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

Bluebook
Blackwell v. United States, (E.D. Mo. 2024).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

WADE WESLEY BLACKWELL, ) ) Petitioner, ) ) v. ) Case No. 4:21CV46 HEA ) UNITED STATES OF AMERICA, ) ) Respondent. )

OPINION, MEMORANDUM AND ORDER This matter is before the Court on Petitioner Wade Wesley Blackwell’s Motion to Vacate, Set Aside or Correct Sentence pursuant to 28 U.S.C. § 2255 [Doc. No. 1]. The United States of America has responded to the Motion pursuant to the Court’s Show Cause Order. For the reasons set forth below, the Motion will be denied. Factual Background The factual background is set forth in the record, the Guilty Plea Agreement, and the United States of America’s Response. Procedural Background Petitioner filed his Motion to Vacate, Set Aside or Correct Sentence pursuant to 28 U.S.C. § 2255, on January 11, 2021. possessing an unregistered shotgun with an illegal overall length less than twenty- six inches in violation of 26 U.S.C. §§ 5845 and 5861(d). On June 10, 2020, Petitioner pleaded guilty to the single count. Petitioner was sentenced to a term of

imprisonment of 33 months followed by a two-year term of supervised release. On January 10, 2023, the Court granted Petitioner’s Motion for Early Termination of Supervised Release. Pursuant to the Agreement, Petitioner also agreed to “waive all rights

to appeal all non-jurisdictional, non-sentencing issues, including, but not limited to, any issues relating to pretrial motions, discovery, the guilty plea, the constitutionality of the statute(s) to which defendant is pleading guilty and whether

defendant’s conduct falls within the scope of the statute(s).” Petitioner also agreed to waive all rights to contest the conviction or sentence in any post- conviction proceeding, including one pursuant to 28 USC, § 2255, except for claims of prosecutorial misconduct or ineffective assistance of counsel.

During the change of plea hearing, Petitioner, who was under oath, confirmed that he was satisfied with the representation he received from his attorney, understood the consequences of pleading guilty, and had reviewed and

understood the terms of the Agreement. Petitioner admitted that he was guilty of each of the elements for the crimes to which he was pleading guilty, and the

2 Petitioner did not appeal his conviction or sentence. Legal Standards Relief Under 28 U.S.C. §2255

A federal prisoner seeking relief from a sentence under 28 U.S.C. § 2255 on the ground “that the sentence was imposed in violation of the Constitution or laws of the United States, or that 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, may move the court which imposed the sentence to vacate, set aside or correct the sentence.” 28 U.S.C. § 2255. Federal habeas relief is limited to rectifying “jurisdictional errors, constitutional errors, and

errors of law.” Raymond v. United States, 933 F.3d 988, 991 (8th Cir. 2019). Errors of law, moreover, only constitute grounds for relief under § 2255 when such error “constitute[s] a fundamental defect which inherently results in a complete miscarriage of justice.” United States v. Addonizio, 442 U.S. 178, 185 (1979)

(internal quotation omitted). Movant bears the burden to prove he is entitled to relief. Golinveaux v. United States, 915 F.3d 564, 567 (8th Cir. 2019). Ineffective Assistance of Counsel

“The standard set forth in Strickland v. Washington, 466 U.S. 668, 104 S. Ct. 2052, 80 L.E.2d 674 (1984), provides the framework for evaluating [Movant’s] ineffective-assistance-of-counsel claim.” Anderson v. United States, 762 F.3d 787, 792 (8th Cir. 2014). [Movant] “must show that his 3 result” to prove a violation of his Sixth Amendment rights. Id. “Deficient performance is that which falls below the range of competence demanded of attorneys in criminal cases.” Bass v. United States, 655 F.3d 758, 760 (8th Cir. 2011) (internal quotation omitted). “Strickland sets a ‘high bar’ for unreasonable assistance.” Love [v. United States], 949 F.3d [406], 410 [8th Cir. 2020] (quoting Buck v. Davis, 137 S. Ct. 759, 775 (2017)). Only a performance “outside the wide range of reasonable professional assistance” is constitutionally deficient. Id. (internal quotation omitted). “We make every effort to eliminate the distorting effects of hindsight and consider performance from counsel’s perspective at the time.” Id. (internal quotation omitted). “Prejudice requires the movant to establish ‘a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different. A reasonable probability is a probability sufficient to undermine confidence in the outcome.’” Bass, 655 F.3d at 760 (quoting Strickland, 446 U.S. at 694). O'Neil v. United States, 966 F.3d 764, 770-71 (8th Cir. 2020). It is well-established that a petitioner’s ineffective assistance of counsel claim is properly raised under 28 U.S.C. § 2255 rather than on direct appeal. United States v. Davis, 452 F.3d 991, 994 (8th Cir.2006); United States v. Cordy, 560 F.3d 808, 817 (8th Cir. 2009). The burden of demonstrating ineffective assistance of counsel is on a defendant. United States v. Cronic, 466 U.S. 648, 658 (1984); United States v. White, 341 F.3d 673, 678 (8th Cir.2003). Both parts of the Strickland test must be met in order for an ineffective assistance of counsel claim to succeed. Anderson v. United States, 393 F.3d 749, 753 (8th Cir. 2005), cert. denied, 546 U.S. 882 (2005). The first part of the test 4 functioning as the counsel guaranteed the defendant by the Sixth Amendment.” Id. Review of counsel’s performance by the court is highly deferential, and the Court “presumes counsel’s conduct falls within the wide range of reasonable professional

assistance.” Id. The Court does not second-guess trial strategy or rely on the benefit of hindsight, id., and the attorney’s conduct must fall below an objective standard of reasonableness to be found ineffective, United States v. Ledezma- Rodriguez, 423 F.3d 830, 836 (8th Cir. 2005). If the underlying claim (i.e., the

alleged deficient performance) would have been rejected, counsel's performance is not deficient. Carter v.

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Related

United States v. Addonizio
442 U.S. 178 (Supreme Court, 1979)
United States v. Cronic
466 U.S. 648 (Supreme Court, 1984)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Hill v. Lockhart
474 U.S. 52 (Supreme Court, 1985)
Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
Miller-El v. Cockrell
537 U.S. 322 (Supreme Court, 2003)
Nathaniel Wade v. Bill Armontrout
798 F.2d 304 (Eighth Circuit, 1986)
Duane Wendall Larson v. United States
905 F.2d 218 (Eighth Circuit, 1990)
Bass v. United States
655 F.3d 758 (Eighth Circuit, 2011)
James F. Shaw v. United States
24 F.3d 1040 (Eighth Circuit, 1994)
John Alvin Payne v. United States
78 F.3d 343 (Eighth Circuit, 1996)
Victor Carter v. Frank X. Hopkins
92 F.3d 666 (Eighth Circuit, 1996)
United States v. Monica Ann White
341 F.3d 673 (Eighth Circuit, 2003)
Randy Anderson v. United States
393 F.3d 749 (Eighth Circuit, 2005)
United States v. Mark T. Davis
452 F.3d 991 (Eighth Circuit, 2006)
Terrick Alfred Williams v. United States
452 F.3d 1009 (Eighth Circuit, 2006)
United States v. Cordy
560 F.3d 808 (Eighth Circuit, 2009)
Buck v. Davis
580 U.S. 100 (Supreme Court, 2017)

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Blackwell v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/blackwell-v-united-states-moed-2024.