Bridges v. United States

CourtDistrict Court, N.D. Iowa
DecidedJune 30, 2023
Docket1:23-cv-00003
StatusUnknown

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

Bluebook
Bridges v. United States, (N.D. Iowa 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF IOWA CEDAR RAPIDS DIVISION

MATTHEW SHAWN VICTOR No. 23-CV-3-CJW-MAR BRIDGES, (No. 20-CR-108-CJW-MAR) Petitioner, ORDER vs. UNITED STATES OF AMERICA, Respondent. __________________________ TABLE OF CONTENTS

I. INTRODUCTION .......................................................................... 3

II. RELEVANT BACKGROUND ........................................................... 3

III. STANDARDS FOR RELIEF ............................................................18

A. Section 2255 Standard .............................................................18

B. Ineffective Assistance of Counsel Standard ....................................19

IV. ANALYSIS ..................................................................................20

A. Request for Evidentiary Hearing ................................................21

B. Advice to Plead Guilty ............................................................22

C. Failing to Investigate ..............................................................24

D. Failure to Attempt to Suppress Evidence ......................................26

E. Misrepresenting the Likely Sentence ...........................................27 F. Failure to File Appeal .............................................................27

V. CERTIFICATE OF APPEALABILITY ................................................28

VI. CONCLUSION .............................................................................28 I. INTRODUCTION This matter is before the Court on petitioner’s January 13, 2023 Motion to Vacate, Set Aside or Correct Sentence. (Doc. 1).1 On February 23, 2023, the Court conducted an initial review of petitioner’s motion, appointed counsel to represent petitioner, ordered petitioner’s former attorney to file an affidavit addressing allegations of ineffective assistance of counsel, and ordering the parties fully brief the merits of petitioner’s allegations. (Doc. 5). As of June 2, 2023, all parties timely and fully complied with the Court’s order.2 The Court has now conducted a full review of petitioner’s motion on the merits. For the following reasons, the Court denies all but one of petitioner’s claims on the merits, finding an evidentiary hearing unnecessary because the record is sufficient to resolve the issues. As to petitioner’s allegation that he requested his attorney file an appeal, the Court will conduct an evidentiary hearing on that claim alone. That hearing is scheduled for August 25, 2023. (See Doc. 26). II. RELEVANT BACKGROUND On December 15, 2020, a grand jury returned a six-count indictment against petitioner, charging him with conspiracy to distribute a controlled substance (Count 1), two counts of possession with the intent to distribute a controlled substance (Counts 2 and 5), and three counts of possessing a firearm as a felon (Counts 3, 4, and 6). (Crim. Doc. 2). On December 18, 2020, the Court appointed a federal public defender to represent petitioner. (Crim. Doc. 7). On the same day, petitioner made his initial appearance, and the Court scheduled trial for February 16, 2021. (Crim. Docs. 8; 11).

1 References to “Doc.” are to docket entries in this case, 23-CV-0003-CJW-MAR. References to “Crim. Doc.” are to docket entries in the underlying criminal case (20-CR-108-CJW-MAR).

2 The Court notes that petitioner filed his own pro se response to the government’s brief and asked for production of documents. (Doc. 18). The Court appointed counsel to represent petitioner, and so the Court will not acknowledge petitioner’s pro se pleadings. Petitioner cannot at once be represented by an attorney and file documents pro se. On January 14, 2021, the Court granted petitioner’s motion to continue the trial. (Crim. Docs. 19; 20). On January 29, 2021, petitioner filed a motion to suppress evidence. (Crim. Doc. 25). In that motion, petitioner argued that the police seized his car without probable cause. (Crim. Doc. 25-1, at 5-7). As the Honorable Mark A. Roberts, United States Magistrate Judge explained in his Report and Recommendation (“R&R”), the single issue was factually complex. The single issue raised by Defendant is the warrantless seizure of the purple Kia Optima he was driving on February 16, 2020. The parties disagree regarding whether that seizure was supported by probable cause when Sergeant Wegg seized it. The Government contends that, even if law enforcement lacked probable cause for the seizure, evidence obtained from the vehicle pursuant to a later search warrant should not be suppressed because of the good-faith exception under United States v. Leon, 468 U.S. 897, 922 (1984). Thus, the legal issues presented are at least straightforward. The facts are more complicated. The seizure followed a February 15, 2020 home invasion or burglary by Defendant and others. However, the facts for the Court to consider stretch back to January 3, 2020 when a police encounter resulted in the impoundment of a black Hyundai Elantra owned by Defendant’s girlfriend, Nyjaya Foster. Sergeant Wegg testified regarding both events. In addition, Sergeant Wegg’s investigation continued after the February 16, 2020 seizure of Defendant’s vehicle. Sergeant Wegg obtained a warrant to search Defendant’s vehicle on February 27, 2020. His affidavit in support of the warrant application thus contains information that came to the attention of law enforcement after Defendant’s vehicle was seized on February 16. This affidavit is in evidence along with Sergeant Wegg’s testimony from the February 24, 2021 hearing, and the transcript of a July 30, 2020 deposition he gave in an Iowa District Court criminal prosecution of Defendant. One challenge presented to the Court is teasing out from these sources what law enforcement (principally in the person of Sergeant Wegg) knew at the time of the seizure.

(Crim. Doc. 36, at 3-4 (footnote omitted)). The Court adopted Judge Roberts’ R&R and denied petitioner’s motion to suppress the evidence. (Crim. Doc. 65). On March 26, 2021, the Court granted petitioner’s second motion to continue the trial, rescheduling it for June 1, 2021. (Crim. Doc. 35). On May 21, 2021, on the eve of trial, the Assistant Federal Public Defender filed a motion to withdraw as counsel having discovered a conflict of interest. (Crim. Doc. 105). The Court granted the motion and appointed new counsel for petitioner. (Crim. Docs. 109; 110). On May 26, 2021, however, attorney Murdoch entered his appearance on behalf of petitioner, having been retained; appointed counsel moved to withdraw, and the Court granted that motion. (Crim. Docs. 112; 113; 114; 115; 116; 117). On May 28, 2021, the Court granted petitioner’s third motion to continue the trial date, setting the new trial date for September 13, 2021. (Crim. Doc. 120). On August 23, 2021, petitioner filed a notice of intent to plead guilty. (Crim. Doc. 131). Petitioner filed a motion to continue on August 30, 2021, stating that although petitioner signed a plea agreement with the government, there was a delay in getting the signed plea agreement to petitioner’s attorney, as explained by his attorney:

On August 20, 2021, Mr. Bridges executed the Plea Agreement, and mailed it to counsel’s office on the same date. On August 23, 2021, Mr. Bridges filed his Notice of Intent to Plead Guilty. ECF No. 131. On August 26, 2021, Thursday, undersigned counsel spoke with Mr. Bridges and further confirmed all above. However, as of the evening of August 28, 2021, counsel has not received the plea paperwork. Counsel is currently in touch with the Government while awaiting the delivery of the plea paperwork, and is coordinating other options so to obtain another copy of executed Plea Agreement.

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