Cobbs v. United States

CourtDistrict Court, D. New Mexico
DecidedMay 7, 2025
Docket1:23-cv-00825
StatusUnknown

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

Bluebook
Cobbs v. United States, (D.N.M. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF NEW MEXICO

RYAN TYREL COBBS,

Petitioner,

v. No. 1:23-cv-00825 KG/GJF No. 5:21-cr-00720 KG UNITED STATES OF AMERICA,

Respondent.

MEMORANDUM OPINION AND ORDER

This matter comes before the Court upon Ryan Tyrel Cobbs’ Motion Under 28 U.S.C. Section 2255 to Vacate, Set Aside, or Correct Sentence by a Person in Federal Custody. (Doc. 1) (Motion).1 Petitioner is a federal prisoner and proceeding pro se. He asks the Court to vacate his firearm convictions based on ineffective assistance of pretrial and sentencing counsel. The United States responded with supporting supplemental materials, (Doc. 9), and Mr. Cobbs filed a Reply, (Doc. 10). Having reviewed the record, the supplemental materials filed by the United States, and the relevant law, the Court will dismiss the Motion and deny a certificate of appealability. I. Background On August 2, 2020, officers with the Hobbs Police Department executed a search warrant at Mr. Cobbs’ house to find a stolen cell phone. The search revealed seven firearms, including a sawed-off shotgun, ammunition, methamphetamine, scales, empty baggies, and a pill bottle full of small rubber bands. Two of the firearms had been reported stolen. Mr. Cobbs was a

1 Citations to (Doc. __) are to documents filed in the Civil Case No. 1:23-cv-825, and citations to (Cr. Doc. __) are to documents filed in the Criminal Case No. 5:21-cr-720. convicted felon. On October 18, 2021, Mr. Cobbs pleaded guilty to one count of felon in possession of a firearm in violation of 18 U.S.C. § 922(g), and one count of possession of an unregistered firearm in violation of 26 U.S.C. §§ 5861(d) and 5871. (Cr. Doc. 22). On September 1, 2022, the Court accepted the plea without the benefit of a plea agreement. (Cr. Doc. 46) (Sentencing

Transcript). Mr. Cobbs was sentenced to a total term of 57 months imprisonment and 3 years of supervised release. (Cr. Doc. 38) (Judgment). He did not appeal. Mr. Cobbs timely filed the instant Motion pursuant to Section 2255. In claim one, he contends his pretrial counsel was ineffective for failing to: (1) inform him of the relevant circumstances and likely consequences of pleading guilty as opposed to proceeding to trial, (2) conduct a proper pretrial investigation; and (3) negotiate a more favorable plea agreement. In claim two, he asserts his sentencing counsel was ineffective for failing to: (1) properly explain the presentence investigation report (“PSR”) prior to his sentencing; (2) file objections to the PSR; and (3) file a notice of appeal. The Court notes he was represented by the same attorney

for both his plea and sentencing. II. Discussion A petition under Section 2255 attacks the legality of a federal prisoner’s detention. Bradshaw v. Story, 86 F.3d 164, 166 (10th Cir. 1996). Relief is available where “the sentence was imposed in violation of the Constitution or laws of the United States,” including the Sixth Amendment right to effective counsel. 28 U.S.C. § 2255(a). See also U.S. v. Tucker, 745 F.3d 1054, 1066 (10th Cir. 2014) (“Sixth Amendment claims asserting ineffective assistance of counsel can and generally must be brought in a habeas action for post-conviction relief under 28

2 U.S.C. § 2255.”). A successful ineffective assistance of counsel claim must meet the two-prong test set forth in Strickland v. Washington, 466 U.S. 668, 687 (1984). First, the petitioner must show “[c]ounsel’s performance was deficient” and contained “errors so serious that counsel was not functioning as the ‘counsel’ guaranteed the defendant by the Sixth Amendment.” Id. at 688. In

other words, the representation must fall below an objective standard of reasonableness based on prevailing professional norms. Id. at 687-88. The Court is required to “eliminate the distorting effects of hindsight” and “indulge a strong presumption that counsel acted reasonably.” Welch v. Workman, 639 F.3d at 980, 1012 (10th Cir. 2011) (quotations omitted). The question to determine deficient performance “is whether [the] representation amounted to incompetence under ‘prevailing professional norms,’ not whether it deviated from best practices or most common custom.” Simpson v. Carpenter, 912 F.3d 542, 593 (10th Cir. 2018) (quoting Harrington v. Richter, 562 U.S. 86, 105 (2011)); Williamson v. Ward, 110 F.3d 1508, 1514 (10th Cir. 1997) (“There is a strong presumption that counsel’s performance falls within the wide

range of professional assistance, the defendant bears the burden of proving that counsel’s representation was unreasonable under prevailing professional norms and that the challenged action was not sound strategy.”) (citations omitted). The second prong of Strickland requires the petitioner to affirmatively prove the deficient performance prejudiced the defense. Battenfield v. Gibson, 236 F.3d 1215, 1234 (10th Cir. 2001) (citing Strickland, 466 U.S. at 693-693). The movant must establish prejudice by showing “that there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different.” Id. at 694. In the context of pleas, the

3 petitioner must “show that there is a reasonable probability that, but for counsel’s errors, he would not have pleaded guilty and would have insisted on going to trial.” Hill v. Lockhart, 474 U.S. 52, 58-59 (1985). See also Lafler v. Cooper, 566 U.S. 156, 163 (2012) (“[A] defendant must show the outcome of the plea process would have been different with competent advice”). Courts may analyze either prong first and need only address one prong if the movant fails to

make a sufficient showing on that prong. Id. at 697. A. Claim 1: Ineffective Assistance of Pretrial Counsel 1. Failure to Communicate the Consequences of Pleading Guilty Mr. Cobbs contends his counsel, Mr. Imtiaz Hossain, was ineffective for failing to inform him of the consequences of pleading guilty as opposed to proceeding to trial. (Doc. 1) at 5. He claims there was a lack of “reasonable communication” between himself and his counsel, which prevented him from participating in his defense. (Doc. 2) at 13. Mr. Cobbs argues that Mr. Hossain “failed to provide any strategic plans as to how they could fight his case,” and should not have discouraged him from proceeding to trial based on the “pure

assumption” that “he would be charged severely.” Id. at 13-14. “The procedures under which a challenged plea was taken play an important . . . role in determining the validity of the plea.” Tovar Mendoza v. Hatch, 620 F.3d 1261, 1269 (10th Cir. 2010). “[T]he representations of the defendant, his lawyer, and the prosecutor at [a plea hearing], as well as any findings made by the judge accepting the plea, constitute a formidable barrier in any subsequent collateral proceedings.” Id. (quoting Blackledge v. Allison, 431 U.S.

Related

United States v. Nyhuis
211 F.3d 1340 (Eleventh Circuit, 2000)
Chandler v. Moore
240 F.3d 907 (Eleventh Circuit, 2001)
MacHibroda v. United States
368 U.S. 487 (Supreme Court, 1962)
Blackledge v. Allison
431 U.S. 63 (Supreme Court, 1977)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Hill v. Lockhart
474 U.S. 52 (Supreme Court, 1985)
Roe v. Flores-Ortega
528 U.S. 470 (Supreme Court, 2000)
Miller-El v. Cockrell
537 U.S. 322 (Supreme Court, 2003)
Bradshaw v. Story
86 F.3d 164 (Tenth Circuit, 1996)
Battenfield v. Gibson
236 F.3d 1215 (Tenth Circuit, 2001)
United States v. Orange
447 F.3d 792 (Tenth Circuit, 2006)
In Re Lindsey
582 F.3d 1173 (Tenth Circuit, 2009)
Tovar Mendoza v. Hatch
620 F.3d 1261 (Tenth Circuit, 2010)
Harrington v. Richter
131 S. Ct. 770 (Supreme Court, 2011)
United States v. Garcia
413 F. App'x 57 (Tenth Circuit, 2011)
United States v. Segun Ashimi
932 F.2d 643 (Seventh Circuit, 1991)
Dennis Wayne Moore v. United States
950 F.2d 656 (Tenth Circuit, 1991)
Lafler v. Cooper
132 S. Ct. 1376 (Supreme Court, 2012)
United States v. Damon Keith Fisher
38 F.3d 1144 (Tenth Circuit, 1994)

Cite This Page — Counsel Stack

Bluebook (online)
Cobbs v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cobbs-v-united-states-nmd-2025.