Doe v. United States

District Court, D. Nevada·Decided April 9, 2024·No. 2:23-cv-01143·Unknown

Opinion

United States of America, Case No. 2:19-cr-00136-KJD-BNW No. 2:23-cv-01143-KJD Respondent/Plaintiff, Order v. Danielle Lacharis Buck, Petitioner/Defendant. Presently before the Court is Movant’s pro se Motion to Vacate, Set Aside, or Correct Sentence under 28 U.S.C. § 2255 (#65). The Government did not file a response. For the reasons stated below, Movant’s motion is denied. I. Factual and Procedural Background On October 26, 2021, Danielle Buck (“Buck”) pled guilty to mail fraud and aggravated identity theft under 18 U.S.C. § 1341 and 18 U.S.C. § 1028A(a)(1). (#46). On May 10, 2022, the Court sentenced Buck to twenty-one (21) months imprisonment for mail fraud and twenty-four (24) months imprisonment for aggravated identity theft, for a total of forty-five (45) months, followed by thirty-six (36) months of supervised release. (#61/64). Buck did not appeal her conviction, so her judgment became final fourteen days later on May 24, 2022. Buck now requests that the Court vacate her 24-month sentence under 28 U.S.C. § 2255, asserting that her aggravated identity theft conviction now invalid in light of in Dubin v. United States, 599 U.S. 110 (2023). (#65). II. Legal Standard 28 U.S.C. § 2255 allows a federal prisoner to seek relief under four grounds: (1) “the sentence was imposed in violation of the Constitution or laws of the United States;” (2) “the court was without jurisdiction to impose such a sentence;” (3) “the sentence was in excess of the maximum authorized by law;” and (4) the sentence is “otherwise subject to collateral attack.” 28 U.S.C. § 2255(a). Motions filed pursuant to 28 U.S.C. § 2255 are subject to a one-year limitations period. 28 U.S.C. § 2255(f). As relevant here, the limitations period runs from the latest of “the date on which the judgment of conviction becomes final” or “the date on which the right asserted was initially recognized by the Supreme Court, if that right has been newly recognized by the Supreme Court and made retroactively applicable to cases on collateral review[.]” 28 U.S.C. § 2255(f)(1), (3). III. Analysis On July 20, 2023, Buck filed this motion to vacate, arguing that because identity theft was not the crux of her case, but rather fraud was, a conviction under 18 U.S.C. § 1028A(a)(1) is not warranted, relying on the Supreme Court’s holding in Dubin as support for her argument. (#65, at 1). Before addressing the merits of Buck’s argument, the Court must first determine whether her motion is timely, and upon review, the Court finds it untimely. A. Timeliness Under 28 U.S.C. § 2255(f) Although the Court must construe pro se pleadings liberally, “pro se litigants are bound by the rules of procedure.” Ghazali v. Moran, 46 F.3d 52, 54 (9th Cir. 1995). As stated above, Buck’s motion could be considered timely in either of two ways. See 28 U.S.C. § 2255(f)(1), (3). First, under § 2255(f)(1), because her judgment became final on May 24, 2022, she had to file her motion no later than May 24, 2023, for it to be considered timely. See 28 U.S.C. § 2255(f)(1). It is undisputed that Buck filed her motion on July 20, 2023, approximately fifty- seven (57) days after the one-year period of limitations had expired. (#65, at 1). Therefore, Buck’s motion is untimely under 28 U.S.C. § 2255(f)(1). Second, under § 2255(f)(3), Buck’s motion could be considered timely if it was filed within one year of the “date on which the right asserted was initially recognized by the Supreme Court, if that right has been newly recognized by the Supreme Court and made retroactively applicable to cases on collateral review.” 28 U.S.C. § 2255(f)(3). While Buck does argue that her sentence must be vacated after Dubin, she makes no argument that Dubin recognized a new right that would be retroactively applicable.1 (See #65, at 1). Moreover, assuming, without deciding, that Dubin did recognize a new right, Buck’s argument would still fail because nothing in that opinion was made retroactive to cases on collateral review. See 599 U.S. at 110; cf. Welch v.

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