Carr v. United States

CourtDistrict Court, M.D. Florida
DecidedSeptember 8, 2025
Docket8:24-cv-01368
StatusUnknown

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

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Carr v. United States, (M.D. Fla. 2025).

Opinion

`UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION

NATHANIEL KEITH CARR, Prisoner, v. Case No. 8:24-cv-1368−KKM−AAS Case No. 8:22-cr-153-KKM-AAS UNITED STATES OF AMERICA, Respondent. ____________________________________

ORDER Prisoner Nathanial Keith Carr moves to vacate his convictions for conspiracy to commit Hobbs Act robbery, Hobbs Act robbery, and using a firearm during a crime a violence, for which he serves 318 months. See 28 U.S.C. § 2255. Carr claims that counsel rendered constitutionally ineffective assistance and that the United States breached the parties’ plea agreement. Because his claims lack merit, Carr’s motion to vacate is denied. I. Background Under a plea agreement, Carr pleaded guilty to one count of conspiracy to commit Hobbs Act robbery, in violation of 18 U.S.C. § 1951(a) and (b) (Count One); two counts of Hobbs Act robbery, in violation of 18 U.S.C. § 1951(a) and (b) (Counts Two and Four); and two counts of using, carrying, and brandishing a firearm during and in relation to a crime of violence, in violation of 18 U.S.C. §924(c)(1)(A) (Counts Three and Five). (Crim. Docs. 71 and 136.) The United States agreed to recommend a downward departure from the sentencing guidelines range if it determined that Carr provided substantial assistance in the investigation or prosecution of others. (Id. at 5–6.) The presentence report calculated an advisory

guidelines range of 135 to 168 months for Counts One, Two, and Four, based on Carr’s total offense level of 30 and his criminal history category of IV. (Crim. Doc. 207 at ¶ 155 and 157.) Carr also faced two consecutive mandatory sentences of 84 months for Counts Three and Five. (Id. at ¶¶ 155 and 156.) At sentencing, the district court described Carr’s culpability as “mid-range” compared to his codefendants’ culpability before sentencing him to a total of 318 months. (Crim. Doc. 395 at 34.) The sentence consists of

150 months for Counts One, Two, and Four, followed by two consecutive terms of 84 months for Counts Three and Five. (Crim. Doc. 216 at 3.) Carr filed no appeal. He now moves to vacate his convictions and sentence and claims that counsel rendered constitutionally ineffective assistance by not adequately explaining the plea agreement (Ground One), by grossly misrepresenting his sentencing exposure (Ground Two), and by submitting an inadequate sentencing memorandum (Ground Three). He further claims that the United States breached the cooperation provision of

the plea agreement (Ground Four). He wishes to withdraw his guilty plea. (Civ. Doc. 1 at 23.) The United States responds that Carr’s claims lack merit. (Civ. Doc. 3.) An earlier order notifies Carr that he may reply no later than thirty days after the United States responds. (Civ. Doc. 2.) The United States filed its response on August 12, 2024. To date, Carr has not replied nor sought an extension of time to do so. II. Legal Standards

Section 2255 allows a federal prisoner to “bring a collateral challenge by moving the sentencing court to vacate, set aside, or correct the sentence.” Winthrop-Redin v. United States, 767 F.3d 1210, 1215–16 (11th Cir. 2014). But “[o]nce the defendant’s chance to appeal has been waived or exhausted, [a court is] entitled to presume he stands fairly and finally convicted, especially when . . . he already has had a fair opportunity to present his federal claims to a federal forum.” United States v. Frady, 456 U.S. 152, 164 (1982). “[A]

collateral challenge, such as a § 2255 motion, may not be a surrogate for a direct appeal.” Lynn v. United States, 365 F.3d 1225, 1232 (11th Cir. 2004) (per curiam) (citing Frady, 456 U.S. at 165). Because collateral review is not a substitute for direct appeal, a defendant must raise on direct appeal all available claims. Relief under Section 2255 is reserved “for transgressions of constitutional rights and for that narrow compass of other injury that could not have been raised in 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) (quoting United States v. Capua, 656 F.2d 1033, 1037 (5th Cir. Unit A Sep. 1981)). For example, a claim of ineffective assistance of counsel is a claim that “should usually be raised in a motion under 28 U.S.C. § 2255.” United States v. Curbelo, 726 F.3d 1260, 1267(11th Cir. 2013). “[T]he cases in which habeas petitioners can properly prevail on the ground of ineffective assistance of counsel are few and far between.” Waters v. Thomas, 46 F.3d 1506, 1511 (11th Cir. 1995) (en banc) (quoting Rogers v.

Zant, 13 F.3d 384, 386 (11th Cir. 1994)). As Sims v. Singletary, 155 F.3d 1297, 1305 (11th Cir. 1998), explains, Strickland v. Washington, 466 U.S. 668 (1984), governs an ineffective assistance of counsel claim: The law regarding ineffective assistance of counsel claims is well settled and well documented. In Strickland v. Washington, 466 U.S. 668, 104 S. Ct. 2052, 80 L. Ed. 2d 674 (1984), the Supreme Court set forth a two-part test for analyzing ineffective assistance of counsel claims. According to Strickland, first, the defendant must show that counsel’s performance was deficient. This requires showing that counsel made errors so serious that counsel was not functioning as the “counsel” guaranteed the defendant by the Sixth Amendment. Second, the defendant must show that the deficient performance prejudiced the defense. This requires showing that counsel’s errors were so serious as to deprive the defendant of a fair trial, a trial whose result is reliable. Strickland, 466 U.S. at 687, 104 S. Ct. 2052.

Strickland requires proof of both deficient performance and consequent prejudice. Strickland, 466 U.S. at 697 (“There is no reason for a court deciding an ineffective assistance claim . . . to address both components of the inquiry if the defendant makes an insufficient showing on one.”); Sims, 155 F.3d at 1305 (“When applying Strickland, we are free to dispose of ineffectiveness claims on either of its two grounds.”). “[C]ounsel is strongly presumed to have rendered adequate assistance and made all significant decisions in the exercise of reasonable professional judgment.” Strickland, 466 U.S. at 690.

“[A] court deciding an actual ineffectiveness claim must judge the reasonableness of counsel’s challenged conduct on the facts of the particular case, viewed as of the time of counsel’s conduct.” 466 U.S. at 690. Strickland requires that “in light of all the circumstances, the identified acts or omissions were outside the wide range of professionally competent assistance.” 466 U.S. at 690. Carr must demonstrate that counsel’s alleged error prejudiced the

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