Daggett v. United States

CourtDistrict Court, E.D. Missouri
DecidedSeptember 30, 2024
Docket1:21-cv-00067
StatusUnknown

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

Bluebook
Daggett v. United States, (E.D. Mo. 2024).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI SOUTHEASTERN DIVISION

SHAWN DEL DAGGETT, ) ) Petitioner, ) ) v. ) Case No. 1:21-CV-67-SNLJ ) UNITED STATES OF AMERICA, ) ) Respondent. )

MEMORANDUM AND ORDER This matter comes before the Court on Petitioner Shawn Del Daggett’s Motion Under 28 U.S.C. § 2255 to Vacate, Set Aside, or Correct Sentence. In a filing docketed on April 21, 2021, Daggett indicated his desire to raise four claims alleging the ineffective assistance of trial counsel, as well as a due-process claim that his sentence was “excessive because it now carries with it additional penalties” due to the COVID-19 pandemic. [Doc. 1 at 8-9.] This Court directed petitioner to refile his motion on a Section 2255 form, and petitioner filed an Amended Motion to Vacate that developed the original four ineffective-assistance claims, added two new ones, and attempted to convert the “COVID-19 excessive punishment” argument into a due-process claim under Rehaif v. United States, 139 S. Ct. 2191 (2019). [Doc. 3.] The parties engaged in extensive briefing on the timeliness of petitioner’s claims, and then this Court ordered the Government to address the merits of Daggett’s claims. [Doc. 24.] This matter is now fully briefed and ready for disposition. BACKGROUND On December 12, 2018, law enforcement officers investigating a burglary and

theft developed a lead indicating Daggett was involved in the offenses. A group of officers drove to Daggett’s home in Poplar Bluff, Missouri. When the officers arrived, they saw Daggett and a woman outside the residence. Daggett and the woman fled and evaded officers for hours before being caught. Later that day, officers executed a search warrant at Daggett’s residence. Inside, they found more than 20 rounds of ammunition (some in a box with Daggett’s ID),

methamphetamine, and materials associated with a meth lab. Officers also searched a vehicle that Daggett abandoned, which was linked to the burglary, and discovered burglary tools, meth residue, and additional ammunition. Subsequent examination confirmed the ammunition had travelled in interstate commerce prior to Daggett’s possession. Additionally, Daggett admitted both that he was

a convicted felon and that he knew about his prohibited status at the time he possessed the ammo. Indeed, his Presentence Investigation Report details four prior felony convictions—including a crime of violence and a controlled substance offense—for which he served more than 3 years in prison. A federal grand jury charged Daggett with one count of possessing ammunition as

a convicted felon, in violation of 18 U.S.C. § 922(g)(1). Daggett ultimately pleaded guilty to a Superseding Information with the same charge but that included the knowledge-of- status element recognized in Rehaif. Specifically, “in exchange for [Daggett’s] voluntary plea of guilty to the . . . Superseding Information,” the Government “agree[d] that no further federal prosecution will be brought in this District relative to [his possession of ammunition]” or the controlled substances and drug paraphernalia found at his residence.

Additionally, the parties made a binding sentencing recommendation of 110 months under Rule 11(c)(1)(C). As part of this agreement, Daggett “waive[ed] all rights to contest the conviction or sentence in any post-conviction proceeding . . . except for claims of prosecutorial misconduct or ineffective assistance of counsel.” At his change- of-plea hearing, the Court ensured that Daggett was competent and that his plea was voluntary, knowing, and supported by a factual basis. The Court then accepted his guilty

plea. On November 18, 2019, the Court sentenced Daggett to the jointly recommended sentence of 110 months’ imprisonment. Daggett confirmed that he did not want to file an appeal the same day, and no notice of appeal was ever filed. Thus, Daggett’s conviction became final on December 2, 2019.

Over the next nine months, Daggett requested a copy of his docket sheet and a § 2255 form; both were sent to him twice at FCC Yazoo City. In November 2020, with his deadline approaching, Daggett moved for an extension of time to file a motion to vacate. The Court denied that request because Daggett failed to include any substantive allegations that could support a postconviction challenge.

Daggett then moved for reconsideration of the extension denial. The Court again denied the extension for want of jurisdiction, but it directed the Clerk’s Office to docket the motion to reconsider as a new § 2255 case. 1 In his motion, Daggett identified five specific “issues that [he] will be raising on his § 2255”: a “due process violation”

claiming excessive punishment and four claims of ineffective assistance of counsel for failing to provide discovery, insufficiently investigating witnesses, declining to file a motion to suppress, and providing inadequate advice to plead guilty. In October 2021, Daggett filed an Amended Motion to Vacate on a § 2255 form. In it, Daggett renewed three ineffective-assistance claims (regarding discovery, pretrial motions, and the guilty plea), added new allegations that counsel failed to file a notice of appeal and failed to

object at sentencing, and attempted to convert his due-process challenge for excessive punishment to a Rehaif claim. The motion for reconsideration was dated November 24, 2020, but this Court did not receive it until December 28, 2020. Had the motion been mailed on November 24, it would have been a timely § 2255 motion. However, it is not clear when the motion was actually mailed because it does not bear a stamp showing

when Daggett submitted it to the prison’s mail room. There is also no date showing when the post office received the envelope. The government contends that this Court should reject this postconviction challenge because petitioner’s claims are untimely, the new allegations in the amended motion do not relate back to the motion for reconsideration, the Rehaif argument is barred

by a postconviction waiver, and each claim otherwise fails on the merits.

1 This Court denied the motion for reconsideration by Order of April 21, 2021 (Doc. 53 in the criminal case) but directed the Clerk to file it as a new § 2255 motion because it contains substantive claims. Thus, the first filing in the civil case was filed on April 21, 2021. LEGAL STANDARD “Section 2255 was intended to afford federal prisoners a remedy identical in scope

to federal habeas corpus.” Sun Bear v. United States, 644 F.3d 700, 704 (8th Cir. 2011) (en banc) (quotation omitted). And like habeas corpus, this statutory remedy “does not encompass all claimed errors in conviction and sentencing.” Id. (quoting United States v. Addonizio, 442 U.S. 178, 185 (1979)). Pursuant to 28 U.S.C. § 2255, a federal prisoner may seek relief from a sentence imposed against him on grounds that “the sentence was imposed in violation of the Constitution or law of the United States, or that the court was

without jurisdiction to impose such sentence, or that the sentence was in excess of the maximum authorized by law or is otherwise subject to collateral attack.” 28 U.S.C. § 2255. The petitioner bears the burden of proof as to each asserted ground for relief. Golinveaux v. United States, 915 F.3d 564, 567 (8th Cir. 2019) (citation omitted).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

United States v. Addonizio
442 U.S. 178 (Supreme Court, 1979)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Dodd v. United States
614 F.3d 512 (Eighth Circuit, 2010)
Sun Bear v. United States
644 F.3d 700 (Eighth Circuit, 2011)
United States v. Bruce Wayne Johnson
707 F.2d 317 (Eighth Circuit, 1983)
Thomas J. Ingrassia v. William Armontrout, Warden
902 F.2d 1368 (Eighth Circuit, 1990)
Gray v. Whitley
992 F.2d 324 (Fifth Circuit, 1993)
United States v. Michael Lloyd Craycraft
167 F.3d 451 (Eighth Circuit, 1999)
Eric A. Moore v. United States
173 F.3d 1131 (Eighth Circuit, 1999)
Anthony Wilson Kingsberry v. United States
202 F.3d 1030 (Eighth Circuit, 2000)
Aaron M. Deroo v. United States
223 F.3d 919 (Eighth Circuit, 2000)
John A. Mandacina v. United States
328 F.3d 995 (Eighth Circuit, 2003)
Elliot Ray v. Marc Clements
700 F.3d 993 (Seventh Circuit, 2012)
Rodela-Aguilar v. United States
596 F.3d 457 (Eighth Circuit, 2010)
Cole v. Roper
579 F. Supp. 2d 1246 (E.D. Missouri, 2008)
Gregory Scott Taylor v. United States
792 F.3d 865 (Eighth Circuit, 2015)
United States v. Eloy Vazquez-Garcia
211 F. App'x 544 (Eighth Circuit, 2007)
Jose Alberto Mora-Higuera v. United States
914 F.3d 1152 (Eighth Circuit, 2019)

Cite This Page — Counsel Stack

Bluebook (online)
Daggett v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/daggett-v-united-states-moed-2024.