Dowdell v. United States of America (INMATE 3)

CourtDistrict Court, M.D. Alabama
DecidedMay 25, 2022
Docket3:19-cv-00671
StatusUnknown

This text of Dowdell v. United States of America (INMATE 3) (Dowdell v. United States of America (INMATE 3)) is published on Counsel Stack Legal Research, covering District Court, M.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dowdell v. United States of America (INMATE 3), (M.D. Ala. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA EASTERN DIVISION

KIRSTON JERMAINE DOWDELL, ) ) Petitioner, ) ) v. ) CASE NO. 3:19-CV-671-WKW-KFP ) (WO) UNITED STATES OF AMERICA, ) ) Respondent. )

RECOMMENDATION OF THE MAGISTRATE JUDGE Kirston Jermaine Dowdell is before the Court with his Motion to Vacate, Set Aside, or Correct Sentence under 28 U.S.C. § 2255. Doc. 1.1 For the reasons discussed below, the Magistrate Judge RECOMMENDS that Dowdell’s § 2255 Motion be DENIED without an evidentiary hearing and that this case be DISMISSED with prejudice. I. BACKGROUND In October 2016, officers with the Opelika, Alabama Police Department arrested Dowdell after he admitted that he had placed hidden cameras in bathroom stalls at the Opelika High School football stadium and that he had also downloaded and watched child pornography on his laptop computer.2 Electronic devices seized during a search of

1 References to document numbers of the pleadings, motions, and other materials in the Court file in this § 2255 action, as assigned on the docket sheet by the Clerk of Court, are designated as “Doc.” References to document numbers assigned by the Clerk in the underlying criminal case (Case No. 2:16-cr-554-WKW) are designated as “Crim. Doc.” All pinpoint citations are to the pages of the electronically filed documents in the Court’s CM/ECF filing system, which may not correspond to pagination on the “hard copy” of the document presented for filing. 2 The factual history is summarized from undisputed facts in the presentence investigation report (“PSR”) without further citation. Doc. 10-1. Dowdell’s house were found to contain numerous images and videos of child pornography, and a search of Dowdell’s computer revealed that he searched, received, downloaded, and possessed child pornography from the internet using his computer. In April 2017, Dowdell

was indicted by a Lee County, Alabama grand jury on state charges of aggravated criminal surveillance and production and possession of obscene matter. Doc. 8-5 at 2–4. In September 2017, a federal grand jury in the Middle District of Alabama returned a 28-count indictment charging Dowdell with 4 counts of production of child pornography, 22 counts of attempted production of child pornography, 1 count of receipt of child

pornography, and 1 count of possession of child pornography. 28 U.S.C. §§ 2251(a); 2252A(a)(2), (a)(5)(B). Doc. 8-1. A federal detainer was lodged, and in October 2017, Dowdell, who was being held on the related state charges in the Lee County Jail, appeared before this Court for arraignment under a writ of habeas corpus ad prosequendum. Crim. Docs. 8–11, 14.

On January 5, 2018, Dowdell pled guilty in this Court to Counts 4 and 28 of the indictment, which charged him with production of child pornography in violation of 28 U.S.C. § 2251(a) and possession of child pornography in violation of 28 U.S.C. § 2252A(a)(5)(B), respectively. Doc. 8-3. In exchange for Dowdell’s guilty plea, the government agreed to dismiss the remaining 26 counts. Doc. 8-2 at 5–6. The plea

agreement contained a waiver provision in which Dowdell waived his right to appeal or collaterally attack his sentence except on grounds of ineffective assistance of counsel or prosecutorial misconduct. Id. at 6–7. On October 11, 2018, the district court sentenced Dowdell to concurrent terms of 200 months in prison on each count. Doc. 8-6 at 110–14. Dowdell did not appeal. Dowdell was returned to state custody after his federal sentencing, and the judgment in the federal

case was filed as a detainer. Crim. Doc. 89. In February 2019, Dowdell pled guilty in the state court3 to the state charges of aggravated criminal surveillance and production and possession of obscene matter. Doc. 8-5 at 5–13. The state court sentenced Dowdell to 15 years in prison, with Dowdell to receive credit for any time he served on his federal sentence. Id. at 5, 11–13.

On September 5, 2019, Dowdell, acting pro se, filed this § 2255 motion asserting the following claims: 1. His counsel was ineffective for failing to request at sentencing that the district court order his federal sentence to run concurrently with his anticipated state sentence.

2. Congress exceeded its Commerce Clause authority by regulating his intrastate production and possession of child pornography, and thus federal jurisdiction was improper in his case.

3. There was no proof of his knowledge of the interstate- commerce nexus of his conduct, which was a jurisdictional element of the offenses for which he was convicted.

4. The camera he used to produce images of child pornography did not give federal jurisdiction for the charges against him.

5. He had a constitutional right to possess obscene materials in the privacy of his home.

3 The Circuit Court of Lee County, Alabama. 6. His federal convictions violated the constitutional prohibition against double jeopardy where he was also convicted of related state offenses.

Doc. 1 at 4–10. II. LEGAL STANDARD The grounds for collateral attack on final judgments under 28 U.S.C. § 2255 are limited. A prisoner may have 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. § 2255. See also McKay v. United States, 657 F.3d 1190, 1194, n.8 (11th Cir. 2011). “Relief under 28 U.S.C. § 2255 ‘is reserved for transgressions of constitutional rights and for that narrow compass of other injury that could not have been raised in direct appeal and would, if condoned, result in a complete miscarriage of justice.’” Lynn v. United States, 365 F.3d 1225, 1232 (11th Cir. 2004) (citations omitted). If a court determines a

prisoner is entitled to § 2255 relief, it “shall vacate and set the judgment aside and shall discharge the prisoner or resentence him or grant a new trial or correct the sentence as may appear appropriate.” 28 U.S.C. § 2255(b). The petitioner, not the government, bears the burden to establish that vacatur of the conviction or sentence is required. Beeman v. United States, 871 F.3d 1215, 1221–22 (11th Cir. 2017). III. DISCUSSION A. Counsel’s Failure to Ask District Court to Run Federal Sentence Concurrently with Anticipated State Sentence

Dowdell claims his trial counsel was ineffective for failing to request at sentencing that the district court run his federal sentence concurrently with his anticipated state sentence. Doc. 1 at 4. At the time of his federal sentencing in October 2018, Dowdell had been indicted on related state charges and was facing prosecution on those charges in state court.

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Bluebook (online)
Dowdell v. United States of America (INMATE 3), Counsel Stack Legal Research, https://law.counselstack.com/opinion/dowdell-v-united-states-of-america-inmate-3-almd-2022.