Dudley v. United States

CourtDistrict Court, N.D. Texas
DecidedJune 4, 2025
Docket3:24-cv-01014
StatusUnknown

This text of Dudley v. United States (Dudley v. United States) is published on Counsel Stack Legal Research, covering District Court, N.D. Texas 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. Tex. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

KEENU JAQUAN DUDLEY, #10306-509, § MOVANT, § § V. § CIVIL CASE NO. 3:24-CV-1014-L § (CRIMINAL CASE NO. 3:20-CR-398-L-6) UNITED STATES OF AMERICA, § RESPONDENT. §

FINDINGS, CONCLUSIONS AND RECOMMENDATION OF THE UNITED STATES MAGISTRATE JUDGE Pursuant to 28 U.S.C. § 636(b), Movant Keenu Jaquan Dudley’s pro se motion under 28 U.S.C. § 2255 to vacate sentence was referred to the United States Magistrate Judge for an evidentiary hearing and for the issuance of findings and a recommended disposition on his first ground for relief. Doc. 14; Doc. 2 at 4. An evidentiary hearing was held on March 10, 2025, on the claim that defense counsel provided ineffective assistance by failing to file a notice of appeal as instructed by Dudley. Doc. 30. Upon careful review of the relevant pleadings, the record, and the applicable law, Dudley should be GRANTED an out-of-time appeal. I. BACKGROUND In 2023, Dudley pleaded guilty under a plea agreement to possession with intent to distribute a controlled substance and was sentenced to 168 months’ imprisonment—a downward variance from the 188-235 guideline range. Crim. Doc. 335.1 Dudley did not file a direct appeal but timely filed this § 2255 motion. Doc. 2.

1 All “Crim. Doc.” Citations refer to the related criminal case, United States v. Dudley, No. 3:20- CR-398-L-6 (N.D. Tex. Aug. 8, 2023). All “Doc.” Citations refer to this § 2255 case. Dudley alleges that his trial counsel, Corwin Davis, rendered ineffective assistance by failing to file a notice of appeal as Dudley had requested through his family members. Doc. 2 at 4; Doc. 3 at 6-8. In support of his allegations, Dudley alleges that immediately after sentence was imposed, he attempted to converse with Davis who responded that he would see him at the jail. Doc. 3 at 6. Dudley contends that he “never heard from Mr. Davis or saw him again,”

however. Doc. 3 at 6. Dudley also proffered as support for his claims (1) a copy of an October 2022 letter to Davis requesting that “motion[s]” be filed to contest sentencing evidence and expressing disappointment with Davis’ failure to respond to calls and messages; (2) a copy of an August 10, 2023 letter from Dudley to Davis, which complained about Davis’ failure to visit him at the jail after sentencing, and (3) the notarized statement of Dudley’s apparent family member attesting to her numerous unanswered calls and messages to Davis. Doc. 7 at 3. Considering Dudley’s pro se status, his allegations, and the record evidence, the Court liberally construes Dudley’s allegations and arguments in the original § 2255 pleadings in the interest of justice to allege that Davis failed to (1) file a notice of appeal as Dudley requested and

(2) adequately consult with him about an appeal. See Gomez-Diaz v. United States, 433 F.3d 788, 791 (11th Cir. 2005) (liberally construing pro se § 2255 pleadings to raise both a failure to file a requested notice of appeal and a failure to consult about appeal); cf. United States v. Alaniz, 5 F.4th 632, 638 (5th Cir. 2021) (declining to liberally construe the “original § 2255 materials to encompass failure-to-advise and failure-to-consult claims” only on procedural grounds, to-wit, that a certificate of appealability had been denied on that issue and the court of appeals thus lacked jurisdiction to address that claim).

2 II. APPLICABLE STANDARD The Sixth Amendment guarantees reasonably effective assistance of counsel at all critical stages of a criminal proceeding. See Cuyler v. Sullivan, 446 U.S. 335, 344 (1980). To obtain post-conviction relief on a claim that defense counsel was constitutionally ineffective, a defendant must prove that counsel’s representation “fell below an objective standard of reasonableness” and that any such deficiency was “prejudicial to the defense.” Strickland v.

Washington, 466 U.S. 668, 688, 692 (1984). Failure to establish either deficient performance or prejudice defeats the claim. Id. at 697. In Roe v. Flores-Ortega, 528 U.S. 470, 477 (2000), the United States Supreme Court applied the Strickland test to claims “that counsel was constitutionally ineffective for failing to file a notice of appeal.” The Supreme Court reaffirmed the well-settled rule that “a lawyer who disregards specific instructions from the defendant to file a notice of appeal acts in a manner that is professionally unreasonable.” Flores-Ortega, 528 U.S. at 477 (cited cases omitted); see also Garza v. Idaho, 586 U.S. 232, 242 (2019) (“Where . . . a defendant has expressly requested an appeal, counsel performs deficiently by disregarding the defendant’s instructions.”). Under such circumstances, “prejudice is presumed ‘when counsel’s constitutionally deficient performance

deprives a defendant of an appeal that he otherwise would have taken’” and “‘no further showing from the defendant of the merits of his underlying claims’” is required. Garza, 586 U.S. at 237 (quoting Flores-Ortega, 528 U.S. at 484); United States v. Tapp, 491 F.3d 263, 265-66 (5th Cir. 2007) (finding that the defendant need only show “a reasonable probability that, but for counsel’s failure, he would have timely appealed”). This “presumption applies even when the defendant has signed an appeal waiver.” Garza, 586 U.S. at 237; see also Tapp, 491 F.3d at 266.

3 But even where a defendant does not instruct counsel to file an appeal or clearly convey his desire to appeal, counsel has a constitutional duty to consult with the defendant about an appeal. Flores-Ortega, 528 U.S. at 480. Such a duty arises “when there is reason to think either (1) that a rational defendant would want to appeal (for example, because there are nonfrivolous grounds for appeal), or (2) that this particular defendant reasonably demonstrated to counsel that

he was interested in appealing.” Id. In this context, consulting means “advising the defendant about the advantages and disadvantages of taking an appeal[] and making a reasonable effort to discover the defendant’s wishes.” Id. at 478; United States v. Pham, 722 F.3d 320, 323-24 (5th Cir. 2013). “The existence of a duty to consult is assessed in light of ‘all the information counsel knew or should have known.’” Id. at 324 (quoting Flores-Ortega, 528 U.S. at 480). “Whether the conviction followed a trial or a guilty plea is ‘highly relevant,’ although not determinative, as is whether the defendant waived his right to appeal and whether he received a sentence for which he bargained.” Id. The Supreme Court also anticipated that “district courts would find a duty to consult ‘in the vast majority of cases.’” Id.

In the event counsel does not meet the constitutionally imposed obligation to consult, whether prejudice resulted again turns on whether the defendant can “demonstrate that there is a reasonable probability that, but for counsel’s deficient failure to consult with him about an appeal, he would have timely appealed.” Flores-Ortega, 528 U.S. at 484.

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Related

United States v. West
240 F.3d 456 (Fifth Circuit, 2001)
United States v. Tapp
491 F.3d 263 (Fifth Circuit, 2007)
Francisco Gomez-Diaz v. United States
433 F.3d 788 (Eleventh Circuit, 2005)
Cuyler v. Sullivan
446 U.S. 335 (Supreme Court, 1980)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Roe v. Flores-Ortega
528 U.S. 470 (Supreme Court, 2000)
United States v. Mary Jean Faubion
19 F.3d 226 (Fifth Circuit, 1994)
United States v. Cong Van Pham
722 F.3d 320 (Fifth Circuit, 2013)
Thompson v. United States
504 F.3d 1203 (Eleventh Circuit, 2007)
United States v. Claudia Atehortua-Castro
751 F.3d 280 (Fifth Circuit, 2014)
Garza v. Idaho
586 U.S. 232 (Supreme Court, 2019)
United States v. Alaniz
5 F.4th 632 (Fifth Circuit, 2021)
United States v. Tighe
91 F.4th 771 (Fifth Circuit, 2024)

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Bluebook (online)
Dudley v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dudley-v-united-states-txnd-2025.