Brooks v. United States

CourtDistrict Court, M.D. Tennessee
DecidedFebruary 25, 2025
Docket3:21-cv-00939
StatusUnknown

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

Bluebook
Brooks v. United States, (M.D. Tenn. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION

ANTHONY BROOKS, ) ) Movant, ) ) No. 3:21-cv-00939 v. ) Judge Trauger ) UNITED STATES OF AMERICA, ) ) Respondent. )

MEMORANDUM OPINION AND ORDER

Pending before the court is pro se movant Anthony Brooks’ motion under 28 U.S.C. § 2255 to vacate, set aside, or correct a sentence previously imposed by this court. (Doc. Nos. 1, 22). Brooks is a federal prisoner housed at the Federal Correctional Institution Beaumont in Beaumont, Texas. Pursuant to a Federal Rule of Criminal Procedure 11(c)(1)(C) agreement, Brooks pleaded guilty to conspiracy to participate in a racketeering activity, in violation of 18 U.S.C. § 1962(d), and possession of a firearm in furtherance of a crime of violence, in violation of 18 U.S.C. § 924(c). The agreement provided for a total prison term of 300 months, which the court imposed. The Government has filed an Amended Answer to Brooks’ Section 2255 motion, urging that Brooks is not entitled to relief because: (1) he has failed to establish counsel was deficient and the deficiency prejudiced him; (2) he is precluded from challenging his career offender calculation; (3) his sentence was not disproportional to similarly situated defendants; and (4) the 18 U.S.C. § 3553(a) factors do not warrant an approximate sentence of 12 years. (Doc. No. 35 at PageID# 122). For the following reasons, Brooks’ motion will be denied. I. BACKGROUND Anthony Brooks (hereinafter “Brooks” or “Movant”) joined the Bloods street gang in 2006 and participated in the gang’s racketeering activity, which included drug-trafficking, murder, robbery, assault, and bribery. See United States v. Anthony Brooks, No. 3:10-cr-00163-5 (hereinafter “Criminal Case”), Pre-Sentence Report (“PSR”)1 at ¶ 4. On June 17, 2010, a federal

grand jury in the Middle District of Tennessee indicted Brooks and 25 other individuals for conspiring to participate in racketeering offenses. (Id., Doc. No. 3 at PageID# 7-76). Brooks was later charged with numerous crimes in a Second Superseding Indictment. (Id., Doc. No. 1147 at PageID# 3359-3421). A. The Second Superseding Indictment Count One of the Second Superseding Indictment (“the Indictment”) charged Brooks and others with conspiracy to participate in racketeering activity, in violation of Title 18, United States Code, Section 1962(d). (Id. at PageID# 3359-92). The Indictment alleged 145 overt acts that were committed in furtherance of the RICO conspiracy, including murder, aggravated

assault, and robbery. (Id.) Brooks’ applicable statutory maximum on Count One was increased to life imprisonment2 because the Indictment alleged that the conspiracy “[wa]s based on a racketeering activity for which the maximum penalty includes life imprisonment.” (Id.; see 18 U.S.C. § 1963(a)). Counts Seventeen, Eighteen, and Nineteen related to a rival gang shooting on February 21, 2010. (Id., Doc. No. 1147 at PageID# 3372, 3408-11). Specifically, Count Seventeen charged Brooks with conspiracy to commit murder in aid of racketeering, in violation of 18 U.S.C. § 1959(a)(5). (Id.) Count Eighteen charged Brooks with assault with a dangerous

1 As per the custom of this court, the PSR is docketed in Brooks’ criminal case but is under seal. (See Case No. 3:10- cr-163-5, Doc. No. 1786) (under seal)).

2 RICO Conspiracy, as described in Section 1962, normally carries a statutory maximum of 20 years’ imprisonment. weapon in aid of racketeering, in violation of Title 18, United States Code, Section 1959(a)(3). (Id.) Count Nineteen charged Brooks with using and carrying firearms during and in relation to a crime of violence, in violation of Title 18, United States Code, Section 924(c). (Id.) Counts Twenty and Twenty-Three stemmed from the planned murder of Joedon Bradley and his subsequent beating. (Id. at PageID #3411, 3415). Count Twenty charged Brooks with using and

carrying a firearm during and in relation to a crime of violence on March 10, 2010, in violation of Title 18, United States Code, Section 924(c). (Id. at PageID# 3412). Count Twenty-Three charged Brooks with assault resulting in serious bodily injury in aid of racketeering on March 28, 2010, in violation of 18 U.S.C. § 1959(a)(3). (Id., Doc. No. 1147 at PageID# 3415). Lastly, Count Twenty-Seven charged Brooks with conspiracy to carry firearms during and in relation to crimes of violence, in violation of 18 U.S.C. § 924(o), with the conspiracy spanning a roughly five-year period. (Id. at PageID# 3419). The predicate crimes of violence identified in Count Twenty-Seven were “conspiracy to participate in a racketeering enterprise, murder in aid of racketeering, and assault with a dangerous weapon in aid of racketeering.” (Id.)

B. The Plea Agreement, Presentence Report, Sentence, and Direct Appeal Brooks pleaded guilty to the RICO Conspiracy offense charged in Count One and the Possession of a Firearm in Furtherance of a Crime of Violence offense charged in Count Twenty, pursuant to Rule 11(c)(1)(C) of the Federal Rules of Criminal Procedure. (Plea Agreement, Doc. No. 1269). The United States agreed to dismiss the remaining five counts that charged Brooks with crimes, including Count 19, that would have required an additional 25-year consecutive sentence. (Id. at PageID# 3901-02). The parties recommended a sentence of 240 months on Count One to be served consecutively to the 60-month sentence on Count Twenty, for a total effective term of imprisonment of 300 months. (Id. at PageID# 3910-11). Brooks admitted committing additional crimes charged in the Indictment and alleged in the plea agreement’s factual basis. (Id. at PageID# 3904-08). After Brooks’ pleas of guilty, the U.S. Probation Office prepared a PSR. The PSR concluded that Brooks’ offenses resulted in a Combined Offense level of 35. (PSR ¶ 57). The parties stipulated that Brooks qualified as a career offender under U.S.S.G. § 4B1.1 because his offense of conviction was a crime of violence and he had at least

two qualifying controlled-substance convictions. Based on this career offender determination and the 924(c) conviction, the PSR concluded that Brooks had a Total Offense Level of 34, a Criminal History Category of VI, and a guideline range of 262 to 327 months. (PSR ¶ 104). On May 25, 2012, the trial court accepted the parties’ recommendation and sentenced Brooks to 240 months on Count One to be served consecutively to a 60-month term of imprisonment on Count Twenty, for a total effective sentence of 300 months. (Judgment, Doc. No. 1715 at PageID# 7644-45). The court also granted the United States’ motion to dismiss the remaining counts in which Brooks was charged. (Id.) Brooks filed an appeal on June 9, 2012. (Notice of Appeal, Doc. No. 1776-80). Brooks’

counsel subsequently filed an Anders brief and motion to withdraw from the case. (Case No. 12- 5681, Doc. Nos. 47, 48 (6th Cir. Sept. 26, 2013)).

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