Dumas v. States of America

CourtDistrict Court, M.D. Florida
DecidedApril 2, 2025
Docket8:24-cv-02393
StatusUnknown

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

Bluebook
Dumas v. States of America, (M.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION

ROBERT DAYON DUMAS,

Petitioner, v. Case No. 8:24-cv-2393-TPB-TGW Case No. 8:18-cr-326-TPB-TGW

UNITED STATES OF AMERICA,

Respondent. ____________________________________

ORDER Robert Dayon Dumas files a counseled motion under 28 U.S.C. § 2255 to vacate his convictions and 300-month sentence for five Hobbs Act robberies and discharging a firearm during two of those robberies. (Civ. Doc. 1) He claims his former counsel was ineffective for not challenging the validity of the traffic stop that resulted in his arrest and prosecution. Dumas is entitled to no relief because his claim is untimely and meritless. I. Background Dumas committed five armed robberies in the Tampa suburb of Wesley Chapel in February of 2018. (Crim. Doc. 97-1 and 94) Corporal Andrew Denbo investigated the robberies for the Pasco County Sheriff’s Office. (Crim. Doc. 72 at 8–9) The following month, Corporal Denbo observed Dumas driving a vehicle at a rate above the speed limit and pulled him over. (Id. at 27–29) During his

initial contact with Dumas, Corporal Denbo did not have his department- issued body camera activated. (Id. at 54–55) Corporal Denbo smelled “marijuana coming from within the vehicle” and observed what he believed to be marijuana on the passenger seat. (Id. at 35–37) Dumas told Corporal

Denbo that a bag located on the passenger seat contained a gun. (Id. at 37) Corporal Denbo retrieved the battery for his body camera and activated it. (Id. at 54–55) He searched Dumas’ vehicle and found marijuana, a portable scale, and evidence that linked Dumas to the armed robberies, including shoes,

a mask, and gloves. (Id. at 48–49) Corporal Denbo arrested Dumas for possession of marijuana and transported him to the Sheriff’s Office. (Id. at 52– 56) Dumas eventually provided a full, videotaped confession of his involvement in the armed robberies. (Crim. Doc. 97-2)

A grand jury charged Dumas with five counts of Hobbs Act robbery, in violation of 18 U.S.C. § 1951(a) (Counts One through Five), and two counts of discharging a firearm during two of the robberies, in violation of 18 U.S.C. § 924(c)(1)(A)(ii). (Crim. Doc. 1) Before trial, Dumas moved to suppress all

evidence recovered from the warrantless search of his vehicle and argued that law enforcement lacked probable cause to conduct the search. (Crim. Doc. 43) Dumas also moved to suppress incriminating statements he made after his arrest and argued that he was not properly advised of his Miranda rights. (Id.) Dumas did not challenge the validity of the traffic stop in his motion to

suppress. Corporal Denbo was the only witness at the suppression hearing. During cross-examination, counsel questioned Corporal Denbo’s credibility, including his initial failure to properly activate the department-issued body camera

during the traffic stop. (Crim. Doc. 72 at 58–71, 85, 141–42) Following the hearing, the district court denied the motion to suppress. (Crim. Doc. 80) It found Corporal Denbo credible and ruled that he had probable cause to search Dumas’ vehicle based on the odor of marijuana

emanating from the vehicle. (Id. at 3–4) The district court also ruled that Corporal Denbo’s detection of the odor of marijuana, his observation of marijuana in the vehicle, and Dumas’ admission of using marijuana established sufficient probable cause to support Dumas’ arrest for possession

of marijuana. (Id. at 5–6) Also, the district court ruled that there was no basis to suppress the items related to the robberies because they were found in plain view during the lawful search of the vehicle. (Id. at 4–5) Finally, the district court ruled that incriminating statements made by Dumas were admissible

because he knowingly and voluntarily waived his Miranda rights. (Id. at 6–7) To facilitate his appeal of the district court’s denial of his motion to suppress, Dumas proceeded to a bench trial and stipulated to certain facts about the armed robberies. (Crim. Doc. 97-1) After a short trial, the district court found Dumas guilty of all charges and sentenced him to 300 months.

(Crim. Docs. 94 and 109) On direct appeal, Dumas argued that the district court erred in denying the motion to suppress. He argued that Corporal Denbo lacked credibility, that there was no probable cause to seize the items unrelated to marijuana

possession, and that Corporal Denbo failed to secure a valid Miranda waiver. See United States v. Dumas, No. 21-11341, 2021 WL 3663560 (11th Cir. Aug. 16, 2021). The circuit court rejected Dumas’ arguments and affirmed. See United States v. Dumas, No. 21-11341, 2023 WL 3302878 (11th Cir. May 8,

2023). Next, Dumas filed for a petition for writ of certiorari, which the U.S. Supreme Court denied. See Dumas v. United States, 144 S. Ct. 289 (2023). II. Analysis Dumas now files a counseled motion to vacate his convictions and

sentence and raises one ground for relief. He claims that his former counsel was ineffective for not challenging the validity of the traffic stop in the suppression motion. (Civ. Doc. 1) The United States responds that Dumas’ claim is untimely and meritless. (Civ. Doc. 5) Dumas filed a counseled reply.

(Civ. Doc. 6) A. Dumas’ claim is untimely.

The Antiterrorism and Effective Death Penalty Act (AEDPA) imposes a one-year statute of limitations for filing a § 2255 motion to vacate or correct sentence. 28 U.S.C. § 2255(f). The one-year period runs from the latest of: (1) the date on which the judgment of conviction becomes final;

(2) the date on which the impediment to making a motion created by government al action in violation of the Constitution or laws of the United States is removed, if the movant was prevented from making a motion by such governmental action;

(3) 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; or

(4) the date on which the facts supporting the claim or claims presented could have been discovered through the exercise of due diligence.

28 U.S.C. § 2255(f). Dumas’ judgment of conviction became final on October 10, 2023, when his petition for certiorari review was denied. See Washington v. United States, 243 F. 3d 1299, 1300 (11th Cir. 2001) (explaining that if a prisoner timely petitions for certiorari review, the filing period “begins to run when the Supreme Court denies certiorari or issues a decision on the merits”). Therefore, he had until October 11, 2024, to file his § 2255 motion. However, on Friday, October 11, 2024, the Tampa Division of the Middle District of Florida was closed due to Hurricane Milton, which struck the west

coast of Florida on Wednesday, October 9, 2024. The Tampa Division closed on Tuesday, October 8th, 2024,1 in anticipation of the arrival of the hurricane, and remained closed until it reopened normal operations on Tuesday, October 15, 2024. “[I]f the clerk’s office is inaccessible . . . then the time for filing is

extended to the first accessible day that is not a Saturday, Sunday, or legal holiday[.]” Fed. R. Civ. P. 6(a)(3)(A).

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