Brooks v. Samuel

CourtDistrict Court, M.D. Pennsylvania
DecidedNovember 18, 2021
Docket3:16-cv-02386
StatusUnknown

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

Bluebook
Brooks v. Samuel, (M.D. Pa. 2021).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF PENNSYLVANIA CHARES AARON BROOKS, : CIVIL ACTION NO. 3:16-2386 Petitioner : (JUDGE MANNION) Vv. : CHARLES E. SAMUEL, JR., : Respondent : MEMORANDUM Charles Aaron Brooks, an inmate currently confined in the United States Penitentiary, Victorville, California, filed the above captioned petition for writ of habeas corpus, pursuant to 28 U.S.C. §2241. (Doc. 1). Brooks challenges his federal sentence under the Interstate Agreement on Detainers Act (IADA), the sentencing court's modification of his federal sentence and the BOP’s subsequent sentence computation, four prison disciplinary actions and numerous vague constitutional claims. For relief, Petitioner seeks “dismissal of indictment #95-cr-564-01; 20-year consecutive sentence in count 7 of judgment and conviction on December 18, 1996 be vacated; disciplinary sanctions be expunged; all disciplinary hearing charges reversed; be entitled to all discovery be disclosed to prisoner that bear exonerating evidence in prisoner favor that were hidden in violation of due process of law.” Id. A response (Doc. 16) and traverse (Doc. 18) having been

filed, the petition is ripe for disposition. For the reasons that follow, the Court will deny the petition for writ of habeas corpus. sentence Computation A. Background On September 11, 1995, federal officials arrested Brooks after filing a complaint in the United States District Court for the Eastern District of Pennsylvania charging him with bank robbery and possession of a weapon. (Doc. 16-2 at 7-9, Criminal Docket, E.D. Pa. No. 2:95-mj-00894-1). The complaint was dismissed without prejudice on October 5, 1995. Id. That same day, federal officials indicted Brooks in the United States District Court for the Eastern District of Pennsylvania in Docket No. 2:95-cr- 00564-HB-1, charging him with conspiracy to commit bank robbery and armed bank robbery. (Doc. 16-2 at 14-29, Criminal Docket No. 2:95-cr- 00564-HB-1). On February 29, 1996, federal officials filed a superseding indictment charging Brooks with five counts of armed bank robbery and three counts of use of a firearm during a crime of violence. Id. On July 26, 1996, a jury convicted Brooks on all eight charges. Id.

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On November 13, 1996, the district court issued a judgment, sentencing Brooks to an 802-month term of imprisonment as follows: 5 years on Count(s): 3 to run consecutive to 1, 2, 4, 6, 8 20 years on Count(s): 5 to run consecutive to 1, 2, 4, 6, 8 20 years on Count(s): 7 to run consecutive to 1, 2, 4, 6, 8 60 months on Couni(s): 1 (Doc. 16-2 at 31, Judgment). On December 12, 1996, the United States Attorney’s Office made a motion to correct the written judgment to be in compliance with the oral pronouncement, requiring the twenty-year sentence for Count 7 to be consecutive to Count 1. (Doc. 16-2 at 14-29, Criminal Docket No. 2:95-cr- 00564-HB-1). By Order dated December 17, 1996, the sentencing court, in accordance with Fed. R. Crim. P. 36, stated the sentence on Count 7 is to run consecutive to the sentences on the remaining counts. (Doc. 16-2 at 40, Order). The BOP, in accordance with Program Statement 5880.28, Sentence Computation Manual (CCCA of 1984), and 18 U.S.C. §3585(a), calculated Brooks’ 802-month sentence as commencing on November 13, 1996 (the date the court-imposed sentence) and applied prior custody credit for the period from September 11, 1995 through November 12, 1996, because he

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remained exclusively in federal custody throughout that period which predated his sentence. (Doc. 16-2 at 42-47, Public Information Inmate Data.) Factoring in Petitioner’s projected days of good conduct time, he has a projected release date of May 8, 2055. Id. Petitioner has filed several motions to vacate or set aside, or correct sentence, pursuant to 28 U.S.C. §2255 as well as numerous attempts to pursue a second or successive §2255 motion. (See Doc. 16-2 at 14, Criminal Docket No. 2:95-cr-00564-HB-1). In the instant petition for writ of habeas corpus, Brooks posits two challenges to his conviction and sentence. First, Petitioner claims that the BOP “failed to disclose to [him] a state of Pennsylvania detainer [was] lodged against [him] on September 12, 1996, nor did state officials and failed to disclose indictment 95-cr-564-01, Judgment and Commitment Order.” (Doc. 2 at 1). Petitioner's second argument is that “while [he] had started serving his sentence at Lompoc Penitentiary, the Federal authorities in the absentia of prisoner without notice to prisoner modifi[ed] imposed sentence after seven days after original sentence was imposed.” Id. He further claims that the “Federal authorities did so on December 18, 1996, impose an illegal -4-

sentence’, in violation of Petitioner's due process. Id. For relief, Petitioner seeks dismissal of the “entire indictment in 95-cr-564, because a fundamental injustice occurred that violates substantive rights of the prisoner.” Id. B. Discussion Federal prisoners seeking post conviction relief from their judgment of conviction or the sentence imposed are generally required to bring their collaterai challenges pursuant to 28 U.S.C. §2255. See 28 U.S.C. §2255(e). Section 2255(e) provides that: An application for a writ of habeas corpus [pursuant to '2241] in behalf of a prisoner who is authorized to apply for relief by motion pursuant to ['2255], shall not be entertained if it appears that the applicant has failed to apply for relief by motion, to the court which sentenced him, or that such court has denied him relief, unless it also appears that the remedy by motion is inadequate or ineffective to test the legality of his detention. 28 U.S.C. §2255(e). To that end, the Court of Appeals for the Third Circuit has observed that “[mJotions pursuant to 28 U.S.C. §2255 are the presumptive means by which federal prisoners can challenge their convictions or sentences that are allegedly in violation of the Constitution.” Okereke v. United States, 307 F.3d 117, 120 (3d Cir. 2002) (citing Davis v. United States, 417 U.S. 333, 343 (1974)). Section 2255(e) specifically -5-

prohibits federal courts from entertaining a federal prisoner’s collateral challenge by an application for habeas corpus unless the court finds that a Section 2255 motion is inadequate or ineffective. Okereke, 307 F.3d at 120 (citing In re Dorsainvil, 119 F.3d 245, 251 (3d Cir. 1997)). This safety valve language in Section 2255(e) has been strictly construed. See Application of Galante, 437 F.2d 1164, 1165B66 (3d Cir. 1971) (concluding that unfavorable legal standards in circuit where sentencing court was located do not render Section 2255 remedy inadequate or ineffective); Millan-Diaz v. Parker, 444 F.2d 95, 97 (3d Cir.

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Bluebook (online)
Brooks v. Samuel, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brooks-v-samuel-pamd-2021.