Charles Orange v. United States of America

District Court, E.D. Texas·Decided June 10, 2026·No. 6:24-cv-00013·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION

CHARLES ORANGE, § § Petitioner, § § v. § CIVIL ACTION NO. 6:24-CV-13-RWS-KNM § UNITED STATES OF AMERICA, § § Respondent. §

ORDER ADOPTING REPORT AND RECOMMENDATION OF THE UNITED STATES MAGISTRATE JUDGE Petitioner Charles Orange, a prisoner confined at the Federal Correctional Institute Texarkana, proceeding pro se, filed this 28 U.S.C. § 2255 motion challenging his federal conviction. Docket No. 1. The case was referred to United States Magistrate Judge K. Nicole Mitchell for findings of fact, conclusions of law, and recommendations for disposition of the proceeding. Docket No. 2. I. Procedural History and Background After a jury trial, Petitioner was sentenced to 240 months’ imprisonment—with a term of supervised release for life—for one count of possession of child pornography in violation of 18 U.S.C. § 2252(a)(5)(B). Docket No. 13 at 1–2. Petitioner filed a direct appeal, and the United States Court of Appeals for the Fifth Circuit affirmed the conviction. See United States v. Orange, No. 21-40176, 2023 WL 2755584, at *1 (5th Cir. Apr. 3, 2023). This proceeding followed. Petitioner raises several claims of ineffective assistance of trial and appellate counsel. Docket No. 1. Specifically, he maintains that trial counsel was ineffective in failing to investigate whether his email had been used on Google to access illegal pornography websites. Id. at 11. He also contends that appellate counsel was ineffective in failing to raise several issues on direct appeal, including (1) an alleged Brady violation, (2) a Batson claim, (3) jury bias, (4) his right to confront his accuser, (5) an illegal search and seizure, and (6) prosecutorial misconduct. Id. at 2– 15. The docket reflects that the sole issue on appeal was trial court error—namely, whether the trial court erred in permitting the Government to submit evidence of Petitioner’s prior conviction

for indecency with a child. Docket No. 13 at 1; Orange, 2023 WL 2755584, at *1. On November 24, 2025, Magistrate Judge Mitchell issued a report and recommendation, recommending that Petitioner’s motion be denied and that the case be dismissed with prejudice. Docket No. 13. The magistrate judge also recommended that the Court deny Petitioner’s request for a certificate of appealability sua sponte because Petitioner failed to make a substantial showing of the denial of a constitutional right. Id. at 9–10. After the magistrate judge granted an extension of time in which to do so, Petitioner filed objections. Docket No. 16; Docket No. 20. II. Petitioner’s Objections In his objections, Petitioner first faults the Government for contending that his trial counsel provided adequate representation. Docket No. 20 at 1. He states that he “still believes” that trial counsel’s performance refutes the notion that his performance was effective during trial, as trial

counsel “failed to conduct a proper investigation in the false allegations brought before the court.” Id. Petitioner insists trial counsel was not prepared for trial given his lack of investigation and that during trial counsel’s opening statement, counsel suggested that Petitioner was “guilty but that the all-white jury had to believe that without a reasonable doubt.” Id. Petitioner also claims in his objections that trial counsel was asked “to examine the Samsung phone for finger prints,” but failed to do so. Id. Additionally, Petitioner complains that trial counsel failed to investigate a Wal-Mart receipt and two specific websites—again maintaining that trial counsel did not object to the racial makeup of the jury. Id. Petitioner further insists that trial counsel informed him that he could file a motion under 28 U.S.C. § 2255, which allegedly proves that trial counsel was ineffective—otherwise Petitioner would not have been informed about how to file one. Id. at 1–2. III. Discussion and Analysis Petitioner’s objections are overruled. Though Petitioner maintains that trial counsel was constitutionally ineffective for failing to investigate a Wal-Mart receipt, phone fingerprints,

specific websites, and an “all white jury,” a review of Petitioner’s § 2255 motion reveals that he did not raise these claims with respect to trial counsel until now. Allegations raised for the first time in objections to a magistrate judge’s report and recommendation are not properly before the Court and will not be considered. See United States v. Armstrong, 951 F.2d 626, 630 (5th Cir. 1992); see also Place v. Thomas, 61 F. App’x 120, 2003 WL 342287, *1 (5th Cir. 2003) (unpublished) (“Generally, an issue raised for the first time in an objection to a magistrate judge’s report is not properly before the district court and therefore is not cognizable on appeal.”). Furthermore, a review of Petitioner’s underlying § 2255 motion reveals that, while he did raise these claims regarding appellate counsel, he did not raise them in regard to trial counsel. Docket No. 1 at 11. Rather, Petitioner claimed in his underlying motion that trial counsel was

ineffective for failing to investigate whether his email had been used on Google to access illegal pornography websites. Id. He raised no other claim regarding trial counsel. Id. Accordingly, Petitioner’s objections concerning trial counsel’s ineffectiveness surrounding an alleged “all white jury,” a Wal-Mart receipt, and Samsung fingerprints are not properly before the Court. Docket No. 20 at 1. To the extent Petitioner presents a proper objection regarding the magistrate judge’s rejection of his claim regarding trial counsel’s alleged failure to investigate, claims of ineffective assistance of counsel are evaluated under the Strickland standard. In order to show that counsel was constitutionally ineffective, a petitioner must show both deficient performance and ensuing prejudice. See Strickland v. Washington, 466 U.S. 668, 687-91 (1984). A petitioner alleging ineffective assistance of counsel must show both deficient performance and prejudice. See Charles v. Stephens, 736 F.3d 380, 388 (5th Cir. 2013) (“A failure

to establish either element is fatal to a petitioner’s claim.”) (internal citation omitted). In evaluating whether counsel’s conduct was deficient, the question is whether the attorney’s conduct fell below an objective standard of reasonableness based on “prevailing norms of practice.” See Loden v. McCarty, 778 F.3d 484, 494 (5th Cir. 2015) (internal citation omitted). Moreover, to establish prejudice, a petitioner must show that there is a reasonable probability that—absent counsel’s deficient performance—the outcome or result of the proceedings would have been different. Id. And it is well-settled that a “reasonable probability” is one that is sufficient to undermine confidence in the outcome of the proceedings. Strickland, 466 U.S. at 694. Turning directly to Petitioner’s allegations, to show that counsel was ineffective in failing to investigate, a petitioner must allege with specificity what the investigation would have revealed

and how it would have changed the outcome of the trial. Docket No. 13 at 5 (citing United States v. Green, 882 F.2d 999

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Charles Orange v. United States of America, (E.D. Tex. 2026).

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