Canales, Victor v. United States

CourtDistrict Court, S.D. Florida
DecidedApril 8, 2025
Docket1:24-cv-24505
StatusUnknown

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

Bluebook
Canales, Victor v. United States, (S.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

CASE NO. 24-cv-24505-ALTMAN 23-cr-20356-ALTMAN-1

VICTOR CANALES,

Movant,

v.

UNITED STATES OF AMERICA,

Respondent. __________________________________/

ORDER Victor Canales pled guilty to possessing a firearm and ammunition after he’d been convicted of a felony. See Judgment, United States v. Canales, No. 23-20356-CR-ALTMAN (S.D. Fla. May 17, 2024), ECF No. 41 at 1. For this crime, we sentenced Canales to 13 months in federal prison. See id. at 2. Canales has now filed a motion to vacate under 28 U.S.C. § 2255, challenging the constitutionality of his conviction and sentence. See Motion to Vacate (“Motion”) [ECF No. 1]. The Respondent filed a Response [ECF No. 11], and Canales never replied. After careful review, we DENY the Motion. THE FACTS On August 31, 2023, a grand jury in our District charged Victor Canales with one count of possession of a firearm and ammunition by a convicted felon. See Indictment, United States v. Canales, No. 23-20356-CR-ALTMAN (S.D. Fla. Sept. 1, 2023), ECF No. 1 at 1. The Government alleged that, “[o]n or about November 23, 2022, in Miami-Dade County, . . . [Canales] knowingly possessed a firearm and ammunition in and affecting interstate and foreign commerce, knowing that he had previously been convicted of a crime punishable by imprisonment for a term exceeding one year,” in violation of 18 U.S.C. § 922(g)(1). Ibid. At his arraignment, Canales entered a not-guilty plea. See Court Minutes, United States v. Canales, No. 23-20356-CR-ALTMAN (S.D. Fla. Sept. 19, 2023), ECF No. 8 at 1. At that time, Canales was facing a prosecution in state court over the same conduct. In December 2022, state authorities had filed an information in the Eleventh Judicial Circuit Court in and for Miami-Dade County, Florida, charging Canales with two crimes: one count of possession of a firearm by a convicted felon, in violation of Florida Statutes § 790.23(1); and one count of carrying

a concealed firearm before July 1, 2023, in violation of Florida Statutes § 790.01(2). See Information, State v. Canales, No. 13-2022-CF-021585 (Fla. 11th Cir. Ct. Dec. 19, 2022), DIN No. 10. Back in our Court, Canales filed a motion to dismiss the Indictment (“MTD”), arguing that 18 U.S.C. § 922(g)(1) was “unconstitutional” both facially and “as applied to” him. MTD, United States v. Canales, No. 23-20356-CR-ALTMAN (S.D. Fla. Nov. 28, 2023), ECF No. 19 at 2 (“Though Mr. Canales does have some prior felony convictions, the nature of those felonies is not sufficiently severe to justify his permanent disarmament.”); see also id. at 4–5 (“It is likewise plausible to suggest that . . . there was a split among the majority justices [in New York Rifle and Pistol Ass’n, Inc. v. Bruen, 597 U.S. 1 (2022)] [on] whether the new Bruen test would pose problems for felon disarmament statutes.” (cleaned up)). On January 23, 2024, we rejected both arguments and denied Canales’s motion. See Order Denying MTD, United States v. Canales, No. 23-20356-CR-ALTMAN (S.D. Fla. Jan. 23, 2024), ECF No. 27.

On February 26, 2024, Canales pled guilty to the Indictment. See Change of Plea H’rg Tr., United States v. Canales, No. 23-20356-CR-ALTMAN (S.D. Fla. Dec. 4, 2024), ECF No. 45. Canales signed a Factual Proffer, admitting that he had knowingly possessed “a black Smith and Wesson firearm” with “eight rounds of ammunition and one round in the chamber,” both of which had been “manufactured outside Florida” and “traveled through interstate or foreign commerce.” Factual Proffer, United States v. Canales, No. 23-20356-CR-ALTMAN (S.D. Fla. Feb. 26, 2024), ECF No. 31 at 1–2. Canales also admitted that “he knew that he had previously been convicted of a felony” when he possessed the firearm. Id. at 2. At his change-of-plea hearing, Canales and the Government modified the Factual Proffer only to delete the part that said detectives had seen Canales “smoking a suspected marijuana cigarette” in his vehicle. Change of Plea H’rg Tr., United States v. Canales, No. 23-20356-CR-ALTMAN (S.D. Fla. Dec. 4, 2024), ECF No. 45 at 40:15–16. After conferring with his lawyer, Canales testified that the

factual proffer was correct. See id. at 40:21–23 (“[The Court:] So with that removed, sir, is what is in the factual proffer correct? [Canales:] Yes, ma’am.” (cleaned up)). Then-sitting U.S. Magistrate Judge Jacqueline Becerra recommended that we accept Canales’s guilty plea, finding that Canales was “fully competent and capable of entering an informed plea,” that Canales “was aware of the nature of the charges and the consequences of the plea,” and that his guilty plea was “a knowing and voluntary plea supported by an independent basis in fact containing each of the essential elements of the offense.” Report and Recommendation on Change of Plea, United States v. Canales, No. 23-20356-CR-ALTMAN (S.D. Fla. Feb. 26, 2024), ECF No. 32 ¶ 6. We adopted her recommendation and adjudicated Canales guilty. See Paperless Order [ECF No. 35]. On May 17, 2024, we sentenced Canales to 13 months in prison—to be followed by a three- year term of supervised release. See Judgment, United States v. Canales, No. 23-20356-CR-ALTMAN (S.D. Fla. May 17, 2024), ECF No. 41 at 2–3. Canales did not appeal his conviction and sentence.

Instead, he filed this Motion to Vacate under 28 U.S.C. § 2255, alleging three grounds for relief. See Motion [ECF No. 1]. The Respondent filed a Response [ECF No. 11]. Canales never filed a Reply. See generally Docket. The Motion is now ripe for review. THE LAW A. Motions to Vacate Under 28 U.S.C. § 2255 Because collateral review isn’t a substitute for a direct appeal, a movant can proceed under § 2255 only in extremely limited circumstances. As relevant here, a prisoner is entitled to relief under § 2255 if (1) “the sentence was imposed in violation of the Constitution or laws of the United States,” (2) “the court was without jurisdiction to impose such sentence,” (3) “the sentence was in excess of the maximum authorized by law,” or (4) the sentence is “otherwise subject to collateral attack.” § 2255(a); accord McKay v. United States, 657 F.3d 1190, 1194 n.8 (11th Cir. 2011). In other words, “relief under § 2255 is reserved for transgressions of constitutional rights and for that narrow compass of

other injuries that could not have been raised on direct appeal and would, if condoned, result in a complete miscarriage of justice.” Richards v. United States, 837 F.2d 965, 966 (11th Cir. 1988) (cleaned up); see also United States v. Frady, 456 U.S. 152, 165 (1982) (“[W]e have long and consistently affirmed that a collateral challenge will not do service for an appeal.”). If a court grants a § 2255 claim, the court “shall vacate and set aside the judgment and shall discharge the prisoner or resentence him or grant a new trial or correct the sentence as may appear appropriate.” § 2255(b). The movant bears the burden of proving his § 2255 claim. See Beeman v. United States, 871 F.3d 1215, 1222 (11th Cir. 2017) (“We rest our conclusion that a § 2255 movant must prove his [claim] on a long line of authority holding that a § 2255 movant bears the burden to prove the claims in his § 2255 motion.” (cleaned up)), cert. denied, 139 S. Ct. 1168 (2019). B.

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