Colvin v. United States

CourtDistrict Court, N.D. Alabama
DecidedJuly 18, 2024
Docket7:22-cv-08003
StatusUnknown

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

Bluebook
Colvin v. United States, (N.D. Ala. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ALABAMA WESTERN DIVISION

JOSEPH LAYMOND COLVIN, ) ) Petitioner, ) ) vs. ) 7:22-cv-08003-LSC ) (7:17-cr-00521-LSC-HNJ) ) UNITED STATES OF AMERICA, ) ) Respondent. )

MEMORANDUM OF OPINION I. Introduction Before this Court is a motion by Joseph Laymond Colvin (“Colvin” or “Petitioner”) to vacate, set aside, or correct his sentence pursuant to 28 U.S.C. § 2255. (Doc. 1.) The Government has responded in opposition to the motion. (Doc. 9.) For the reasons set forth below, Colvin’s § 2255 motion is due to be denied and this action dismissed without an evidentiary hearing. Colvin also has several other pending motions. On September 1, 2022, Colvin filed a motion to supplement his § 2255 motion with an additional ground. (Doc. 8.) For reasons set forth below, this motion to supplement is denied. Additionally, Colvin filed a request for a 90-day extension for his original § 2255 motion in December of 2021. (Cr. Doc.1 61.) Because his original § 2255 motion has been

timely filed, an extension is not necessary and his request for an extension is moot. Lastly, he filed a motion for an evidentiary hearing. (Doc. 13.) Because this Court

finds a hearing is not necessary and his action is due to be dismissed, his motion for an evidentiary hearing (doc. 13) is also denied. II. Background

A. Charges and Sentencing In November of 2017, Colvin was indicted on one count of felon in possession of a firearm, in violation of 18 U.S.C. § 922(g)(1). (Cr. Doc. 1.) In October of 2018,

he filed a motion to suppress the evidence obtained by police officers in the encounter, asserting a violation of his Fourth Amendment rights. (Cr. Doc. 24.)

Following a hearing, the motion to suppress was denied, and Colvin conditionally pled guilty, reserving his right to appeal the denial of the suppression motion. (Cr. Doc. 32.) He was then sentenced to 240 months imprisonment. (Cr. Doc. 44 at 2.)

Colvin appealed to the Eleventh Circuit, where his conviction was affirmed on July 28, 2020, and issued as mandate on November 2, 2020. (Cr. Doc. 58.) During the

1 “Cr. Doc.” refers to an entry on the docket sheet in the underlying criminal case, United States v. Colvin, No. 7:17-cr-521-LSC-HNJ. suppression hearing, he was represented by Stuart Albea. (Doc. 1 at 7.) During sentencing and on appeal, he was represented by Jason Neff. (Id.)

B. § 2255 Proceedings On January 27, 2022, Colvin filed his § 2255 motion. (Doc. 1.) He asserts four

grounds upon which he claims § 2255 relief should be granted, all of which are based on ineffective assistance of counsel. Two of the grounds relate to his representation by Stuart Albea during his suppression hearing, and can be

categorized as follows: 1. Counsel failed to provide requested body camera footage for the hearing, which would have “cleared up all discrepancies as to the stop.” (Doc. 1 at 3.)

2. Counsel failed to investigate the procedure and policy of the Tuscaloosa Police Department related to their use of body cameras. (Id. at 4.)

One of the grounds relates to his representation by Jason Neff during sentencing, and can be divided as follows: 1. Counsel failed to present the defendant’s mental health history and

diagnoses as mitigating factors for his sentence. (Id. at 5.) 2. Counsel failed to request a categorical approach in the analysis of his criminal history as it relates to the Armed Career Criminal Act (ACCA). (Id.) 3. Counsel failed to object to the Government’s decision not to grant him one of the point reductions for acceptance of responsibility. (Id.)

The final ground relates to his representation by Jason Neff during the appeal process, and can be divided as follows:

1. Counsel failed to present an appealable issue of whether there was probable cause to conduct a Terry Stop. (Id. at 6.) 2. Counsel failed to provide body camera footage requested by the defendant.

(Id.) For the reasons outlined below, the Court finds these claims are without merit and due to be denied without an evidentiary hearing.

III. Timeliness Judgment was entered against Colvin on May 28, 2019. (Cr. Doc. 44.) Colvin

appealed to the Eleventh Circuit; and on July 28, 2020, the appeal decision was entered. (Cr. Doc. 58.) The Eleventh Circuit’s decision was then issued as mandate on November 2, 2020. (Id.) Colvin did not file a petition for a writ of certiorari;

therefore, the Eleventh Circuit’s decision became final ninety days after the Eleventh Circuit decision. See SUP. CT. R. 13; see also Michel v. United States, 519 F.3d 1267, 1268 n.1 (11th Cir. 2008) (“When no petition for writ of certiorari is filed,

the judgment becomes final for § 2255 purposes when the time for filing the petition expires. Clay v. United States, 537 U.S. 522, 524 (2003). A petition for writ

of certiorari must be filed within 90 days of the day the appellate court’s judgment was entered.”). “The Court’s control over the judgment below comes to an end after the mandate has been issued.” Meredith v. Fair, 306 F.2d 374, 376 (5th Cir.2

1962). Therefore, the ninety-day period from which the petition for writ of certiorari must be filed began when the Eleventh Circuit declared the mandate. His judgment became final on January 31, 2021. Because Colvin filed his § 2255 motion

on January 27, 2022, which is within one year of the date that the judgment of his conviction became final, the motion is timely. See 28 U.S.C. § 2255(f)(1). Colvin is bringing his first § 2255 motion, so it is not “second or successive”

within the meaning of the Anti-Terrorism and Effective Death Penalty Act of 1996 (“AEDPA”). See id. At § § 2255(h), 2244(b)(3)(A).

Colvin filed a motion to supplement his § 2255 motion with an additional ground on September 1, 2022. (Doc. 8.) Supplemental grounds to a § 2255 motion must also be filed within one year of the final judgment unless they “relate back”

to a previous timely filed § 2255 motion. See, Jeffries v. U.S., 748 F.3d 1310, 1313- 1314 (11th Cir. 2014). Because Colvin’s motion to supplement was filed after

2 Fifth Circuit precedent is binding in the Eleventh Circuit if the decision was handed down before September 30, 1981. Bonner v. Prichard, 661 F.2d 1206, 1207 (11th Cir. 1981). January 31, 2021, it is not timely. It also describes different conduct than that which

is included in his original § 2255 motion, so it does not “relate back” to his original motion. It does not relate to conduct of any of his lawyers. Colvin’s motion to supplement his § 2255 motion (doc. 8) is therefore denied as untimely.

IV. Standard of Review Because collateral review is not a substitute for direct appeal, the grounds for collateral attack on final judgments pursuant to 28 U.S.C. § 2255 are limited. A

petitioner is entitled to relief under § 2255 if the court imposed a sentence that (1) violated the Constitution or laws of the United States, (2) exceeded its jurisdiction, (3) exceeded the maximum authorized by law, or (4) is otherwise subject to

collateral attack. See 28 U.S.C.

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