Duplessis v. United States

CourtDistrict Court, S.D. Illinois
DecidedFebruary 28, 2022
Docket3:21-cv-00095
StatusUnknown

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

Bluebook
Duplessis v. United States, (S.D. Ill. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS

ANDREW M. DUPLESSIS, ) ) Petitioner, ) ) vs. ) Case No. 21-cv-00095-JPG ) UNITED STATES OF AMERICA, ) ) Respondent. )

MEMORANDUM AND ORDER This matter is before the Court on petitioner Andrew M. Duplessis’ (“Petitioner” or “Duplessis”) Motion to Vacate, Set Aside or Correct Sentence pursuant to 28 U.S.C. § 2255. On August 21, 2019. Petitioner pled guilty to one count of possession with intent to distribute methamphetamine. On January 30, 2020, the Court sentenced him to serve 216 months in prison on Count 1 for possession with intent to distribute methamphetamine. He did not appeal his conviction. Duplessis’ criminal Case No. is 19-cr-40047-JPG.1 I. Background In June 2019, a grand jury issued an indictment for Duplessis for Possession with intent to distribute methamphetamine (Crim. Doc. 1). Attorney Robert Elovitz (“Mr. Elovitz”) was appointed to represent Duplessis. Duplessis notified the Court that his final pre-trial would be converted into a change of plea hearing on August 21, 2019. Duplessis pled guilty, in an open plea, on that date and sentencing was scheduled for November 26, 2019 (Crim. Doc. 20). During that hearing, Duplessis, under oath, stated he was fully satisfied with counsel and representation by Mr. Elovitz. (Crim. Doc. 60, p. 4). Additionally, in the colloquy regarding the sentencing

1 Any document referencing the docket in Duplessis’ criminal case shall hereby be referred to as “(Crim. Doc.).” Documents from Duplessis’ civil Section 2255 case shall be referred to as “(Doc.). guidelines, Duplessis stated him, and his attorney spoke about the Federal Sentencing Guidelines and the 18 U.S.C. 3553(a) factors. Id. at 7. Additionally, when asked about the “rough” guideline calculation, Mr. Elovitz stated “Defendant’s criminal history comes into play greatly in this instance.” Id. at 8. Additionally, Mr. Elovitz stated:

The Government has provided two sets of incidents that may affect his relevant conduct, so that the actual potential base offense levels can vary by, in his case, I think -- the Government and I have talked on the methamphetamine issue -- can vary as much as six levels and potentially with other relevant conduct they have disclosed in another report, but we could be at a difference of four levels additional, so we could have a ten-level swing either way at sentencing. It's quite an open range, Judge.

Id. The Court asked if Duplessis understood that he will be able to review the presentence report and make objections to the report. Id. Duplessis stated he understood. Id. at 8-9. A pre-sentence investigation report (“PSR”) was issued on October 21, 2019 (“Initial PSR”). (Crim. Doc. 21). Duplessis had fourteen days to object, which counsel for Duplessis filed on November 4, 2019 (Crim. Doc. 22). The Initial PSR determined Duplessis’ relevant conduct involved 2.7 kilograms methamphetamine in the form of “ice,” recommended two-level firearm enhancement, three-level reduction for acceptance of responsibility, Offense Level 35, and Criminal History Category II. Id. The guideline range was 188-235 months, the statutory maximum term was 20 years. Id. The Government moved to strike Duplessis’ objections. Duplessis objected, stated his relevant conduct was “far below” 2.7 kilograms and objected to the firearm enhancement, stating he never was in possession of handguns “during the time frame in question.” (Crim. Doc. 22). Duplessis also objected to each paragraph with the exception of two paragraphs that amounted to actually involved amounts of ice seized from Duplessis upon his arrest. Id. The Government moved to strike the objections, which this Court denied (Crim. Doc. 23, 35). On December 13, 2019, the Addendum to the Initial PSR was issued (Crim. Doc. 32). The Addendum, issued by U.S. Probation, asserted information and calculations in the Initial PSR were accurate. Id. Mr. Elovitz sought continuation of the sentencing hearing. The Government conducted

additional interviews in response to Duplessis’ relevant conduct and firearm objections. (Doc. 17, p. 8). As a result of these interviews, on January 27, 2020, Probation issued a revised presentence report (“Revised PSR”), whereby the relevant conduct increased from 2.7 kilograms to 3.28 kilograms. (Crim. Doc. 46). The Revised PSR continued to apply the two-level firearm enhancement. Id. During sentencing on January 30, 2020, the Court asked Duplessis if he received the Revised PSR, which he stated he had. (Crim. Doc. 61, p. 3). When asked about the objections to the PSR, Mr. Elovitz stated “Defendant would announce…he’s going to withdraw the objections as to the weight of the sentence in question for relevant conduct purposes.” Id. at 4. When the Court asked Duplessis if that was correct and Duplessis stated “Yes, your Honor.” Duplessis was

still objecting to the firearm enhancement. Id. at 5. On January 30, 2020, the second revised PSR (“Second Revised PSR”) was issued, which corrected the date/year on the fact page and changed “581.175 ounces” to “581.175 grams” in paragraph 15. (Crim. Doc. 47). The Government called three witnesses and introduced letters that Duplessis sent to two of the witnesses while incarcerated. In one letter attached to the Government’s response, Duplessis threatened witness John Reed regarding his cooperation with the Government. (Doc. 17, Exh. C p. 8). Upon consideration of the witnesses and evidence provided, the Court found the firearm enhancement applicable not only “by a preponderance of the evidence, but the evidence is overwhelming that this Defendant was known to possess firearms during drug transactions even though he didn’t show it every time, but it was there.” (Crim. Doc. 61, p. 48-49). Additionally, the Court noted that the letters and threats were “inconsistent with acceptance of responsibility.” Id. at 61. The Court stated it was not going to be taking two points back for acceptance of responsibility but noted it for the record. The Court, in consideration of all the

3553(a) factors, sentenced Duplessis to 216 months in prison. Id. at 63. II. § 2255 Motion In his timely motion, Petitioner raises the following claims of constitutionally ineffective assistance of counsel Robert Elovitz in violation of his Sixth Amendment rights: 1) Attorney Robert Elovitz provided ineffective assistance of counsel by failing to advise petitioner that his sentence could be based on additional “ghost dope” and a firearm enhancement; 2) Attorney Elovitz provided ineffective assistance of counsel by failing to object to the alleged due process violation, specifically, the fact that Duplessis was denied due process because the Revised PSR was not “timely” disclosed.

Additionally, Petitioner also makes a due process claim. Petitioner states he was denied due process because the Revised PSR was not “timely” disclosed. Pursuant to Rule 4(b) of the Rules Governing § 2255 Proceedings for the United States District Courts, the Court has determined that it is plain from the motion and the record of the prior proceedings that Petitioner is not entitled to relief. III. Analysis a. Sixth Amendment The Court must grant a § 2255 motion when a petitioner’s “sentence was imposed in violation of the Constitution or laws of the United States.” 28 U.S.C. § 2255(a). However, “[r]elief under § 2255 is available ‘only in extraordinary situations, such as an error of constitutional or jurisdictional magnitude or where a fundamental defect has occurred which results in a complete miscarriage of justice.’” United States v.

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