BRENT v. United States

CourtDistrict Court, S.D. Indiana
DecidedOctober 24, 2024
Docket1:22-cv-01921
StatusUnknown

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

Bluebook
BRENT v. United States, (S.D. Ind. 2024).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION

SHAWN BRENT, ) ) Petitioner, ) ) v. ) No. 1:22-cv-01921-JPH-MG ) UNITED STATES OF AMERICA, ) ) Respondent. )

ORDER ON MOTION FOR RELIEF UNDER 28 U.S.C. § 2255 Shawn Brent pled guilty to conspiring to distribute 50 grams or more of methamphetamine and was sentenced to 210 months' imprisonment. Mr. Brent asks the Court to vacate his guilty plea and sentence pursuant to 28 U.S.C. § 2255, arguing that he was deprived of his constitutional right to effective assistance of counsel. For the reasons that follow, the motion is denied, except for his claim that his counsel failed to file a notice of appeal despite his instructions to do so. II. Background A grand jury indicted Mr. Brent on three methamphetamine-related charges and one count of possessing a firearm as a convicted felon. Crim. dkt.1 1-2. The Court appointed James Edgar to represent Mr. Brent. Crim. dkt. 38.

1 United States v. Watters, No. 1:20-cr-00318-JPH-TAB-2. A. Plea Agreement Mr. Brent petitioned the Court to plead guilty pursuant to a plea

agreement. Crim. dkt. 46. In it, Mr. Brent agreed to plead guilty to one count of conspiring to possess with intent to distribute and to distribute 50 grams or more of methamphetamine. Id. at ¶ 1. Mr. Brent also waived his right to appeal the conviction and sentence imposed. Id. at ¶ 20. For purposes of calculating the advisory Guidelines' range, Mr. Brent stipulated to a base offense level 36 based on the quantity of controlled substances and a two-level increase for possession of a firearm. Id. at ¶ 19. In exchange, the government agreed to dismiss the remaining counts:

two additional drug charges (carrying ten-year minimum sentences) and one felon-in-possession charge (carrying ten-year maximum sentences). Id. at ¶ 2; see 18 U.S.C. § 924(a)(2) (eff. Dec. 21, 2018–June 24, 2022); 21 U.S.C. § 841(b)(1)(A)(viii) (eff. Dec. 21, 2018–Dec. 1, 2022). The government stipulated that Mr. Brent was entitled to a three-level acceptance-of-responsibility reduction, and agreed to recommend a sentence no higher than the top of the advisory Sentencing Guidelines range. Id. at ¶¶ 10, 19. Mr. Brent stipulated to the following facts:

• Officers seized four pounds of methamphetamine, two ounces of heroin, a drug press, a rifle, and a handgun from his residence. • He personally distributed a total of 157.24 grams of methamphetamine in two separate transactions. • He conspired with another person to distribute methamphetamine. • The conspiracy involved the distribution of at least 1,550 grams of methamphetamine readily foreseeable to Mr. Brent. Id. at ¶ 15. In his plea agreement, Mr. Brent acknowledged that he was waiving his rights to: • a jury trial; • be represented by counsel; • present testimony, evidence, and witnesses; • compel witnesses to appear, if necessary; • confront and cross-examine witnesses; and • appeal any conviction or sentence.

Crim. dkt. 46 at ¶ 9. He further acknowledged that Mr. Edgar: • informed, counseled, and advised him as to the nature and cause of every accusation and possible defense; • discussed the plea agreement with him; • represented him satisfactorily; and • did "all that anyone could to do to counsel and assist" him. Id. at ¶ 25. B. Change of plea and sentencing hearing At the start of the combined change of plea and sentencing hearing, the Court told Mr. Brent to speak up if there was anything covered during the hearing he did not understand, and that he could have a break anytime during the hearing to speak privately with Mr. Edgar. Crim. dkt. 80 at 4:9–15. Mr. Brent confirmed that he was "fully satisfied with the counsel, representation, and advice" Mr. Edgar provided him. Id. at 4:16–20. He also confirmed that he read the entire plea agreement, had an opportunity to review it with Mr. Edgar, and was pleading guilty freely because he was in fact guilty. Id. at 5:2–22. The Court notified Mr. Brent of his constitutional rights, including the

right to a jury trial, to be presumed innocent, to representation by counsel, to confront and cross-examine witnesses, to present evidence and compel the attendance of witnesses, and to avoid self-incrimination. Id. at 7:21–8:22. Mr. Brent acknowledged that he understood he had those rights and further acknowledged his understanding that by entering a guilty plea, he would be waiving those rights. Id. at 8:23–9:9. He also confirmed that he had read the stipulated factual basis and that the facts set forth in it were accurate and true. Id. at 9:10–22. The Court reviewed Mr. Brent's appeal waiver, and Mr.

Brent confirmed on the record that he had discussed the waiver provisions with his attorney and understood what the waiver provisions meant. Id. at 11:15–13:14. The Court accepted Mr. Brent's plea of guilty to one count of conspiring to possess with intent to distribute and to distribute 50 grams or more of methamphetamine. Id. at 13:17–14:6. During the sentencing phase, the Court calculated an advisory Guidelines range of 210–262 months' imprisonment. Crim. dkt. 80 at 18:8–13.

The Court sentenced Mr. Brent to 210 months' imprisonment. Id. at 31:17– 32:6. III. Applicable Law A. 28 U.S.C. § 2255 A motion pursuant to 28 U.S.C. § 2255 is the presumptive means by which a federal prisoner can challenge his conviction or sentence. See Davis v. United States, 417 U.S. 333, 343 (1974). A court may grant relief from a federal conviction or sentence pursuant to § 2255 "upon 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." 28 U.S.C. § 2255(a). "Relief under this statute is available only in extraordinary situations, such as an error of

constitutional or jurisdictional magnitude or where a fundamental defect has occurred which results in a complete miscarriage of justice." Blake v. United States, 723 F.3d 870, 878-79 (7th Cir. 2013) (citing Prewitt v. United States, 83 F.3d 812, 816 (7th Cir. 1996); Barnickel v. United States, 113 F.3d 704, 705 (7th Cir. 1997)). B. Ineffective assistance of counsel A § 2255 movant claiming ineffective assistance bears the burden of showing (1) that counsel's performance fell below objective standards for

reasonably effective representation and (2) that this deficiency prejudiced the defense. Strickland v. Washington, 466 U.S. 668, 688–94 (1984); Resnick v. United States, 7 F.4th 611, 619 (7th Cir. 2021).

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