Dudley v. United States

CourtDistrict Court, N.D. Alabama
DecidedFebruary 1, 2024
Docket7:22-cv-08034
StatusUnknown

This text of Dudley v. United States (Dudley 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
Dudley v. United States, (N.D. Ala. 2024).

Opinion

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

JOSHUA RESHI DUDLEY, ) ) Petitioner, ) ) v. ) 7:22-cv-08034-LSC ) (7:18-cr-00066-LSC-JEO-1) UNITED STATES OF AMERICA, ) ) Respondent. ) MEMORANDUM OF OPINION I. Introduction Before this Court is a motion by Joshua Reshi Dudley (“Dudley” or “Petitioner”) to vacate, set aside, or otherwise correct his sentence, pursuant to 28 U.S.C. § 2255 (“§ 2255”) (Doc. 1.) The United States (“Government”) opposes his motion. (Doc. 10.) Dudley’s § 2255 motion (doc. 1) is due to be denied and the present action dismissed with prejudice for the reasons stated below. II. Background A. Charges and Sentencing

On March 29, 2018, a grand jury charged Dudley in an indictment with felon in possession of a firearm in violation of 18 U.S.C. § 922(g). (Cr. Doc. 1.)1 On May

17, 2018, Dudley entered into a plea agreement and subsequently pled guilty before this Court on May 31, 2018. (Cr. Doc. 12; Minute Entry 05/31/2018.) The Presentence-Investigation Report (“PSR”) stated because he was an

“armed career criminal” based upon 18 U.S.C. § 924(e), his guideline imprisonment range was 188 months to 235 months. (Cr. Doc. 31 at 24, 30.) On January 8, 2019, this Court sentenced Dudley to 215 months of imprisonment to run concurrently

with any yet-to-be imposed sentence in his Tuscaloosa County Circuit Court case. (Cr. Doc. 33 at 2.) Dudley then filed a notice of appeal on January 22, 2019, and the Eleventh Circuit affirmed this Court’s decision on September 24, 2021. (Cr. Docs.

36, 45; US v. Dudley, No. 19-10267.2) Dudley was represented by Allison Case (Ms. Case) at his change of plea

hearing and Mr. Tobie John Smith (Mr. Smith) on appeal. B. § 2255 Proceedings

1 “Cr. Doc.” refers to an entry on the docket sheet in the underlying criminal case, United States v. Dudley, No. 7:18-cr-00066-LSC-JEO-1.

2 In the interest of brevity, the Eleventh Circuit opinion in Dudley’s case will hereina�er be cited as Cr. Doc. 45, which is the document number for the opinion in the underlying criminal case. Dudley filed this pro se § 2255 motion on September 1, 2022.3 (Doc. 1.) He alleges three grounds in his petition, with each having numerous subparts. (Id.)

From what this Court can ascertain, it appears that Dudley is alleging four claims of ineffective assistance of counsel with three of the allegations against only his trial

counsel and one against both trial counsel and appellate counsel; two claims regarding improper jurisdiction pursuant to the Rehaif decision; and one claim based on the enhancement he received pursuant to the Armed Career Criminal Act

(“ACCA”). (Id.) All subparts will be addressed under each of these three broad topics. III. Timeliness and Non-Successiveness of Dudley’s § 2255 Motion

This Court entered Dudley’s judgment on January 8, 2019. (Cr. Doc. 33.) He then filed a �mely no�ce of appeal, with the Eleventh Circuit’s opinion issued on

September 24, 2019. (Cr. Doc. 45.) He then had ninety days to file a writ of cer�orari with the Supreme Court of the United States. See SUP. CT. R. 13. Dudley �mely filed his pe��on with the Supreme Court on December 15, 2021. (S.Ct. No. 21-6657.) On

March 21, 2022, the Supreme Court denied his pe��on for writ of cer�orari,

3 Applying the “mailbox rule,” the Eleventh Circuit deems a prisoner’s § 2255 mo�on as filed upon the “date that he delivered it to prison authori�es for mailing, presump�vely, . . . the day that he signed it.” Jones v. United States, 304 F.3d 1035, 1038 n.7 (11th Cir. 2002) (per curiam). therefore making his convic�on final. (Id.) Thus, he had un�l March 21, 2023 to file

his pe��on to comport with the one-year statute of limita�ons ar�culated in 28 U.S.C. §§ 2255(f). Because he filed his pe��on in September of 2022, his mo�on is �mely.

Addi�onally, Dudley is bringing his first § 2255 mo�on, so it is not “second or successive” within the meaning of the An�-Terrorism and Effec�ve Death Penalty Act of 1996 (“AEDPA”). See 28 U.S.C. §§ 2255(h), 2244(b)(3)(A).

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

pe��oner is en�tled to relief under § 2255 if the court imposed a sentence that (1) violated the Cons�tu�on or laws of the United States, (2) exceeded its jurisdic�on,

(3) exceeded the maximum authorized by law, or (4) is otherwise subject to collateral atack. See 28 U.S.C. § 2255; United States v. Phillips, 225 F.3d 1198, 1199 (11th Cir. 2000); United States v. Walker, 198 F.3d 811, 813 n.5 (11th Cir. 1999).

“Relief under 28 U.S.C. § 2255 ‘is reserved for transgressions of cons�tu�onal 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 jus�ce.’”

Lynn v. United States, 365 F.3d 1225, 1232 (11th Cir. 2004) (quo�ng Richards v. United States, 837 F.2d 965, 966 (11th Cir. 1988)).

In li�ga�on stemming from a § 2255 mo�on, “[a] hearing is not required on patently frivolous claims or those which are based upon unsupported generaliza�ons. Nor is a hearing required where the pe��oner’s allega�ons are

affirma�vely contradicted by the record.” Holmes v. United States, 876 F.2d 1545, 1553 (11th Cir. 1989) (quo�ng Guerra v. United States, 588 F.2d 519, 520–21 (5th Cir. 1979)). However, an eviden�ary hearing is appropriate if, “accept[ing] all of the

pe��oner’s alleged facts as true,” the pe��oner has “allege[d] facts which, if proven, would en�tle him to relief.” Diaz v. United States, 930 F.2d 832, 834 (11th Cir. 1991) (quo�ng Agan v. Dugger, 835 F.2d 1337, 1338 (11th Cir. 1987) and Futch

v. Dugger, 874 F.2d 1483, 1485 (11th Cir. 1989)). V. Discussion

A. Ineffective Assistance of Counsel Claims An ineffec�ve assistance of counsel claim has two components: (1) the pe��oner “must show that the counsel’s performance was deficient” and (2) the

pe��oner “must show that the deficient performance prejudiced the defense.” Strickland v. Washington, 466 U.S. 668, 687 (1984).

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