Christopher Durfee v. United States of America

2020 DNH 061
District Court, D. New Hampshire·Decided April 20, 2020·No. 16-cv-280-JD·Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Christopher Durfee

v. Civil No. 16-cv-280-JD Opinion No. 2020 DNH 061

United States of America

O R D E R

Christopher Durfee was convicted in 1997 on multiple charges of Hobbs Act robbery, attempted robbery, and conspiracy to commit robbery. He was also convicted on two counts of using or carrying a firearm during a crime of violence in violation of 18 U.S.C. § 924(c). He received a sentence of 437 months of imprisonment, of which 300 months are attributable to his convictions on Counts 8 and 15 under § 924(c). Durfee brings a petition pursuant to 28 U.S.C. § 2255, challenging his convictions and sentences on Counts 8 and 15.1

Background2

In 1995 and 1996, Durfee met with several others to plan robberies of various targets, including supermarkets. In early

1 The First Circuit Court of Appeals granted Durfee permission to file a second or successive petition. See Doc. no. 5.

2 The background information is taken from United States v.

LiCausi, 167 F.3d 36 (1st Cir. 1999), which affirmed Durfee’s conviction, along with the convictions of those charged and tried with him.

January of 1996, Durfee and another member of the group, Bernie Subocz, robbed a Vista Foods supermarket in Manchester, New Hampshire. They used pistols to force the store manager to open the safe and escaped with $66,000.00.

In March, Durfee joined other members of the group in two attempts to rob a Market Basket supermarket in Portsmouth, New Hampshire. Durfee was carrying a Beretta semi-automatic pistol during those attempts. The group abandoned the planned robberies because of equipment problems on the first attempt and when the store manager noticed them the second time and made a call on his cell phone.

Four of the robbers, including Durfee, were charged on twenty-seven counts in a superseding indictment. Count 13, which charged conspiracy to commit robbery of the Market Basket supermarket in Portsmouth, was dismissed before trial. Pertinent to the issues raised in this habeas petition, Durfee was convicted of conspiracy to commit robbery of the Vista Foods supermarket in violation of 18 U.S.C. § 371, Count 6; robbery of the Vista Foods supermarket in violation of 18 U.S.C. § 1951 (“Hobbs Act”), Count 7; attempted robbery of Market Basket in violation of § 1951, Count 14; and use of a firearm during a crime of violence in violation of 18 U.S.C. § 924(c)(1); Counts 8 and 15. Durfee’s convictions were affirmed on appeal.

Discussion

Section 924(c)(1)(A) provides increased sentences for any person who “during and in relation to any crime of violence or drug trafficking crime . . . uses or carries a firearm, or who, in furtherance of any such crime, possesses a firearm.” A “crime of violence” for purposes of § 924(c)(1)(A) is a felony that either “(A) has an element the use, attempted use, or threatened use of physical force against the person or property of another, or (B) that by its nature, involves a substantial risk that physical force against the person or property of another may be used in the course of committing the offense.” § 924(c)(3). Crimes of violence for purposes of § 924(c) are known as predicate offenses.

Conspiracy to commit Hobbs Act robbery, the predicate offense at issue in this case, is not a “crime of violence” as defined by § 924(c)(3)(A) because it does not have “as an element the use, or threatened use of physical force against the person or property of another.” See Brown v. United States, 942 F.3d 1069, 1075-76 (11th Cir. 2019); United States v. Barrett, 937 F.3d 126, 127 (2d Cir. 2019); United States v. Simms, 914 F.3d 229, 233-34 (4th Cir. 2019); Kenney v. United States, 2020 WL 869791, at *3 (D.N.H. Feb. 21, 2020). For that reason, to qualify as a predicate offense, a conspiracy to commit Hobbs Act

robbery would have to be a crime of violence under § 924(c)(3)(B).

The Supreme Court recently held that § 924(c)(3)(B), known as the residual clause, is unconstitutionally vague. United States v. Davis, 139 S. Ct. 2319, 2336 (2019). That new substantive rule of constitutional law applies retroactively to cases on collateral review. In re Franklin, 950 F.3d 909, 911 (6th Cir. 2020); Bufkin v. United States, --- F. App’x ---, 2020 WL 405389, at *2 (7th Cir. Jan. 24, 2020); United States v. Bowen, 936 F.3d 1091, 1097-98 (10th Cir. 2019); In re Hammond, 931 F.3d 1032, 1038 (11th Cir. 2019). As a result, offenses that depend on the residual clause to qualify as crimes of violence can no longer serve as predicate offenses for purposes of § 924(c) convictions.

In support of his amended § 2255 motion, Durfee contends that the predicate offenses for the § 924(c) charges, Counts 8 and 15, included Hobbs Act robbery conspiracies that no longer qualify as crimes of violence. Because the jury could have found him guilty on the § 924(c) charges, Counts 8 and 15, based on the conspiracy charges, he argues, his convictions on Counts 8 and 15 must be vacated, and he must be resentenced.3

3 To the extent Durfee intended to rely on structural error, he has not shown it applies here. Structural error is a rare type of constitutional mistake “affecting the framework within

In response, the government agrees that, under Davis, conspiracy to commit Hobbs Act robbery no longer qualifies as a crime of violence for purposes of § 924(c). The government contends, however, that the change does not undermine Durfee’s convictions. The government asserts that the only predicate offense for Count 15, pertaining to the Market Basket supermarket in Portsmouth, was the attempted Hobbs Act robbery charge, Count 14. With respect to the § 924(c) conviction on Count 8, pertaining to robbery of the Vista Foods supermarket in Manchester, the government contends that the robbery conviction on Count 7 provides a predicate offense and that the error in the jury instruction on Count 8, which included the conspiracy charge, is harmless.

which the trial proceeds.” Arizona v. Fulminante, 499 U.S. 279, 310 (1991). When structural error occurs, it is per se prejudicial. United States v. French, 904 F.3d 111, 119 (1st Cir. 2018).

In contrast, an “error which occurred during the presentation of the case to the jury” is not structural. Fulminante, 499 U.S. at 307. For that reason, an error in jury instructions is not structural. United States v. Pelletier, 666 F.3d 1, 11 (1st Cir. 2011). More specifically, “[s]tructural error does not occur when a jury rendering a general verdict ‘was instructed on alternative theories of guilt and may have relied on an invalid one.’” United States v. Jones, 935 F.3d 266, 270 (5th Cir. 2019). Therefore, structural error is not implicated in this case.

A. Standard of Review A motion under § 2255 may be granted if the petitioner shows that his “sentence was imposed in violation of the Constitution or laws of the United States.” § 2255(a). Pertinent to this case, “constitutional error occurs when a jury is instructed on alternative theories of guilt and returns a general verdict that may rest on a legally invalid theory.” Skilling v. United States, 561 U.S. 358, 404 (2010); Hedgpeth v. Pulido, 555 U.S. 57, 61 (2008). On review under § 2255, the harmless error standard applies to constitutional errors due to flawed jury instructions. Neder v. United States, 527 U.S. 1, 9-10 (1999); Oriz-Graulau v. United States, 756 F.3d 12, 20 (1st Cir. 2014); Sustache-Rivera v. United States, 221 F.3d 8, 18 (1st Cir. 2000). More specifically, the harmless error standard applies in § 2255 cases where the petitioner challenges a § 924(c) jury instruction on the ground that it included an invalid predicate offense. United States v. Black, 2020 WL 1445606, at *2 (N.D. Ill. Mar. 25, 2020); Acosta v. United States, 2019 WL 4140943, at *3 (W.D.N.Y. Sept. 2, 2019); Johnson v. United States, 2019 WL 1790218, at *5 (C.D. Ca. Apr. 23, 2019).

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