Busby v. United States

CourtDistrict Court, D. Nevada
DecidedJuly 16, 2025
Docket2:21-cv-02053
StatusUnknown

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

Bluebook
Busby v. United States, (D. Nev. 2025).

Opinion

1 UNITED STATES DISTRICT COURT

2 DISTRICT OF NEVADA

3 UNITED STATES OF AMERICA, 4 Respondent, Case No.: 2:15-cr-00353-GMN-NJK 5 vs. 6 ORDER DENYING PETITIONER’S CHRISTOPHER RYAN BUSBY, § 2255 MOTION FOR INEFFECTIVE 7 ASSISTANCE OF COUNSEL Petitioner. 8

9 10 Pending before the Court is the claim for ineffective assistance of counsel in Petitioner 11 Christopher Ryan Busby’s Motion to Vacate, Set Aside, or Correct Sentence under 28 U.S.C. 12 § 2255 (“§ 2255 Motion”), (ECF No. 184). The Government filed a Response, (ECF No. 197), 13 to which Petitioner replied, (ECF No. 201). Additionally, because the Court conducted an 14 evidentiary hearing for Petitioner’s ineffective assistance of counsel claim, the parties filed a 15 Joint Hearing Brief, (ECF No. 280). 16 Because Petitioner fails to establish that counsels’ performance was deficient under 17 Strickland v. Washington, the Court DENIES Petitioner’s § 2255 Motion. 18 I. BACKGROUND 19 In 2019, Petitioner pled guilty to Count One of the Indictment: receipt of child 20 pornography on his Dell laptop in violation of 18 U.S.C. § 2252(a)(2) and (b). (See Mins. 21 Proceedings, ECF No. 113). Then the Court sentenced Petitioner to custody for 121 months 22 followed by 45 years’ supervised release after finding him guilty of Count One. (See J., ECF 23 No. 137); (Mins. Proceedings, ECF No. 135). In 2021, Petitioner filed the instant § 2255 24 Motion pro se. The Court granted the Government’s motion for an order deeming the attorney- 25 client privilege waived between Petitioner and the former attorneys he is accusing provided 1 constitutionally ineffective assistance. (Order, ECF No. 193). The briefing schedule was then 2 extended to allow attorneys Tony Abbatangelo, Heidi Ojeda, and G. Michael Tanaka to 3 respond to Petitioner’s ineffective assistance of counsel claims. In 2023, the Court entered an 4 Order denying in part, and deferring in part, the § 2255 Motion. (Order, ECF No. 203). The 5 Court deferred ruling on 12 grounds for ineffective assistance of counsel, scheduled an 6 evidentiary hearing to resolve the remaining grounds, and appointed defense counsel for 7 purposes of the hearing. An evidentiary hearing was held on June 30 and July 1, 2025, where 8 the Court heard oral argument from Petitioner’s counsel and the Government as well as witness 9 testimony from trial counsel Tony Abbatangelo, trial counsel Heidi Ojeda, Petitioner 10 Christopher Busby, then-Prosecutor Elhan Roohani, and Las Vegas Metropolitan Police 11 forensic examiner Matthew Trafford. 12 II. LEGAL STANDARD 13 Section 2255 provides, in pertinent part: “A prisoner in custody under sentence of a 14 court established by Act of Congress claiming the right to be released upon the ground that the 15 sentence was imposed in violation of the Constitution or laws of the United States . . . may 16 move the court which imposed the sentence to vacate, set aside or correct the sentence.” See 17 Davis v. United States, 417 U.S. 333, 344–45 (1974). To warrant relief, the prisoner must 18 demonstrate the existence of an error of constitutional magnitude which had a substantial and 19 injurious effect or influence on the guilty plea or the jury’s verdict. See Brecht v. Abrahamson, 20 507 U.S. 619, 637 (1993); see also United States v. Montalvo, 331 F.3d 1052, 1058 (9th Cir. 21 2003) (“Brecht’s harmless error standard applies to habeas cases under section 2255[.]”). 22 Relief is warranted only upon the showing of “a fundamental defect which inherently results in 23 a complete miscarriage of justice.” Davis, 417 U.S. at 346. 24 “The customary procedure for challenging the effectiveness of defense counsel in a 25 federal criminal trial is by collateral attack on the conviction under 28 U.S.C. § 2255.” United 1 States v. Miskinis, 966 F.2d 1263, 1269 (9th Cir.1992) (quoting United States v. Birges, 723 2 F.2d 666, 670 (9th Cir.), cert. denied, 466 U.S. 943 (1984) (alteration omitted)). To prevail on 3 an ineffective assistance of counsel claim, Petitioner must show both (1) deficient performance 4 under an objective standard of reasonableness and (2) prejudice. Strickland v. Washington, 466 5 U.S. 668, 687 (1984). To demonstrate deficient performance, “[t]he challenger’s burden is to 6 show ‘that counsel made errors so serious that counsel was not functioning as the ‘counsel’ 7 guaranteed to the defendant by the Sixth Amendment.’” Harrington v. Richter, 562 U.S. 86, 8 104 (2011) (quoting Strickland, 466 U.S. at 687). Under this analysis, the question is whether 9 “counsel’s representation fell below an objective standard of reasonableness;” and the Court’s 10 inquiry begins with a “strong presumption that counsel’s conduct [falls] within the wide range 11 of reasonable representation.” United States v. Ferreira–Alameda, 815 F.2d 1251, 1253 (9th 12 Cir. 1987) (as amended). “[T]he standard for judging counsel’s representation is a most 13 deferential one” because “the attorney observed the relevant proceedings, knew of materials 14 outside the record, and interacted with the client, with opposing counsel, and with the judge.” 15 Harrington, 562 U.S. at 105. To demonstrate prejudice, the petitioner must show that “but for 16 counsel’s unprofessional errors,” there is a reasonable probability “the result of the proceeding 17 would have been different.” Strickland, 466 U.S. at 694 (“A reasonable probability is a 18 probability sufficient to undermine confidence in the outcome.”). A court need not examine the 19 existence of prejudice if the petitioner fails to establish cause. Engle v. Isaac, 456 U.S. 107, 134 20 n.43 (1982). Moreover, a petitioner must allege facts—not conclusory allegations—to warrant 21 relief. See James v. Borg, 24 F.3d 20, 26 (9th Cir. 1994). 22 III. DISCUSSION 23 Petitioner filed the instant § 2255 Motion pro se, arguing that vacatur of his sentence is 24 warranted for numerous reasons. (See generally § 2255 Mot., ECF No. 184). Because the 25 1 Court entered an Order resolving part of the § 2255 Motion, it need only address the remaining 2 unresolved grounds for Petitioner’s ineffective assistance of counsel claim. 3 Before the Court are 12 remaining grounds for Petitioner’s ineffective assistance of 4 counsel claim: Grounds 1, 3, 5, 6, 7, 7(a), 8, 9, 10, 11, 12, and 17. During the evidentiary 5 hearing, Petitioner’s counsel conceded that many of the grounds were improperly alleged, and 6 attempted to reframe the issue before the Court by arguing that Petitioner did not enter his plea 7 knowingly. Petitioner’s assertion of a legal claim not included in the § 2255 Motion would 8 generally be improper, but because the Government had an opportunity to respond to these 9 arguments at the hearing, the Court finds it fair to consider them. Moreover, because the Court 10 must construe a pro se litigant’s filings liberally, it provides some latitude to Petitioner and will 11 consider the merits of his argument that he entered an involuntary plea as it relates to his 12 existing ineffective assistance of counsel claim.

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Related

Davis v. United States
417 U.S. 333 (Supreme Court, 1974)
Engle v. Isaac
456 U.S. 107 (Supreme Court, 1982)
Brecht v. Abrahamson
507 U.S. 619 (Supreme Court, 1993)
Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
Harrington v. Richter
131 S. Ct. 770 (Supreme Court, 2011)
United States v. Sanchez Barreto
93 F.3d 17 (First Circuit, 1996)
United States v. Acosta
303 F.3d 78 (First Circuit, 2002)
United States v. Flyer
633 F.3d 911 (Ninth Circuit, 2011)
United States v. Constanza Perdomo
800 F.2d 916 (Ninth Circuit, 1986)
United States v. Alejandro Ferreira-Alameda
815 F.2d 1251 (Ninth Circuit, 1987)
United States v. Robert J. Miskinis
966 F.2d 1263 (Ninth Circuit, 1992)
United States v. Thekkedajh Peethamb Menon
24 F.3d 550 (Third Circuit, 1994)
United States v. Chong in Kim
25 F.3d 1426 (Ninth Circuit, 1994)
United States v. Fernando Novelo Nostratis
321 F.3d 1206 (Ninth Circuit, 2003)
United States v. Michael L. Montalvo
331 F.3d 1052 (Ninth Circuit, 2003)
United States v. Ross
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Busby v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/busby-v-united-states-nvd-2025.