Eddington v. United States

CourtDistrict Court, S.D. Illinois
DecidedJuly 7, 2025
Docket3:22-cv-02001
StatusUnknown

This text of Eddington v. United States (Eddington 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
Eddington v. United States, (S.D. Ill. 2025).

Opinion

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

DONVIE SADAN EDDINGTON, SR., ) ) Petitioner, ) ) vs. ) Case No. 3:22-cv-2001-DWD ) UNITED STATES OF AMERICA, ) ) Respondent. )

MEMORANDUM & ORDER

DUGAN, District Judge: In this proceeding, Petitioner requests that the Court vacate, set aside, or correct his sentence under 28 U.S.C. § 2255. (Docs. 1, 3, 10, 22, 24). The Government opposes that request. (Docs. 17 & 23). For the reasons explained below, Petitioner’s request is DENIED. I. BACKGROUND Petitioner pled guilty to being a felon in possession of a firearm and, on August 11, 2021, he was sentenced to 83 months in prison. See U.S. v. Eddington, No. 21-cr-30006- DWD, Docs. 17, 28, 47, 48 (S.D. Ill.). Neither a direct appeal, nor any other petition or application related to the Court’s judgment and conviction, was filed. (Doc. 1, pgs. 1-2). On August 29, 2022, Petitioner filed a Motion to Vacate, Set Aside, or Correct Sentence under § 2255. (Doc. 1). He raised three grounds for relief. (Doc. 1, pgs. 4-6). First, Petitioner cited Roe v. Flores-Ortega, 528 U.S. 470 (2000), to suggest his attorney “Failed to File [a] Notice of Appeal.” (Doc. 1, pg. 4). Second, Petitioner stated he received ineffective assistance due to his counsel’s failure to object to the base offense level under U.S.S.G. § 2K2.1(a)(2). (Doc. 1, pg. 5). Third, Petitioner stated he received ineffective assistance due to his counsel’s failure to object to the criminal history calculation. (Doc. 1, pg. 6).

On September 7, 2022, the Court found Petitioner did not complete the “Supporting facts” sections for his grounds for relief. See Rule 2(b)(2) of the Rules Governing Section 2255 Proceedings in the U.S. District Courts; Estremera v. U.S., 724 F.3d 773, 776 (7th Cir. 2013); (Doc. 2). In other words, Petitioner did not “state the specific facts that support[ed] [his] claim[s].” (Docs. 1, pgs. 4-6; 2). Indeed, Petitioner hardly provided any supporting information at all. (Doc. 1, generally). Therefore, the Court found it was

unable to assess the grounds for relief asserted by Petitioner. See 28 U.S.C. § 2255(b); Rule 4(b) of the Rules Governing Section 2255 Proceedings in the U.S. District Courts. He was directed to file an Amended Motion to rectify these deficiencies. (Doc. 2). On September 29, 2022, Petitioner filed an Amended Motion to Vacate, Set Aside, or Correct Sentence under § 2255. (Doc. 3). With respect to the first ground for relief,

Petitioner argues counsel was ineffective due to his failure to consult petitioner about, and then perfect, an appeal. (Doc. 3, pgs. 6-15). As to the second ground for relief, related to the failure of counsel to object to the base offense level, Petitioner argues he “would have been sentenced to a much lighter sentence” in the absence of the error. (Doc. 3, pgs. 15-18). Petitioner also argues, following Rehaif v. U.S., 588 U.S. 225 (2019), the

Government had to prove he knew he belonged to the relevant category of persons barred from possessing a firearm and that he knew he possessed a firearm. (Doc. 3, pgs. 16-18). As to his third ground for relief, relating to the failure of counsel to object to the criminal history calculation, Petitioner argues he “read his PSR and brought…discrepanc[ies] to the attention of” counsel. (Doc. 3, pgs. 19-22). Petitioner wished to withdraw his open guilty plea; however, he “was advised by counsel that it was to [sic] late to do so.” (Doc.

3, pgs. 22-23). Under these circumstances, Petitioner maintains his open guilty plea was not knowing and voluntary. (Doc. 3, pg. 24). On October 3, 2022, the Court found the Amended Motion survived a preliminary review, so it directed a Response. (Doc. 4). On October 17, 2022, the Government filed a Motion for an Order Authorizing Defense Counsel to Provide a Written Response. (Doc. 5). The Government argued Petitioner’s allegations concern communications between himself and his legal counsel,

Mr. David Brengle. (Doc. 5, pg. 2). The Government further noted it does not know the content of those communications and, absent information from Mr. Brengle, it could not respond to Petitioner’s claims. (Doc. 5, pg. 3). The Government sought a finding that Petitioner, by placing his communications with Mr. Brengle at issue, waived the attorney- client privilege. (Doc. 5, pg. 3). The Government also sought authorization for Mr. Brengle

to file an affidavit in response to the Amended Motion, including information usually protected by the attorney-client privilege. (Doc. 5, pgs. 1, 3). Given the nature of the Government’s Motion, the Court ordered Petitioner to file a Response, but he did not do so. (Docs. 7 & 9). Therefore, on November 14, 2022, the Government filed a Second Motion for an Order Authorizing Defense Counsel to Provide a Written Response. (Doc. 9).

The Court found Petitioner waived the attorney-client privilege with respect to communications, relating to the allegations in the Amended Motion, with Mr. Brengle. (Doc. 11, pg. 2) (citing Garcia v. Zenith Elec. Corp., 58 F.3d 1171, 1175 n.1 (7th Cir. 1995); Staszak v. U.S., No. 15-20, 2015 WL 4474333, *1 (S.D. Ill. July 21, 2015)). The Court granted the Government’s Motions and authorized Mr. Brengle to tender an affidavit in response to Petitioner’s Amended Motion, limited to his communications about the allegations at

issue. (Doc. 11, pgs. 2-3) (citing Seifer v. U.S., 225 F. Supp. 3d 811, 812 (E.D. Wisc. 2016)). On November 14, 2022, Petitioner filed a Motion for Leave to Amend and/or Supplement his Amended Motion under § 2255. (Doc. 10). In resolving that request, which was filed under Federal Rule of Civil Procedure 15, the Court noted Petitioner sought to raise new arguments under New York State Rifle & Pistol Ass’n, Inc. v. Bruen, 597 U.S. 1 (2022). (Docs. 10 & 12). He also included an affidavit that touched upon his first

ground for relief. (Doc. 10, pgs. 9-11; 12). The Court found, while piecemeal amendments to § 2255 motions are discouraged, it would grant Petitioner leave to supplement the Amended Motion. (Doc. 12). The Government was to address all of his claims. (Doc. 12). The Government filed a Response in Opposition to Petitioner’s requested relief on December 21, 2022. (Doc. 17). It takes the position that Petitioner cannot satisfy the

ineffective assistance of counsel inquiry for any of his grounds for relief, arguing: (1) Petitioner was advised of, and consulted on, his right to appeal, but he did not timely request that counsel initiate an appeal; (2) Petitioner’s base offense level was correct, he does not identify a specific error in its calculation under § 2K2.1(a)(2), and counsel cannot be ineffective for the failure to raise a frivolous objection to the application of

§ 2K2.1(a)(2); (3) the Indictment was not violative of Rehaif, Petitioner’s prior statements and convictions indicate he had the requisite knowledge for the underlying conviction, and counsel cannot be ineffective for the failure to raise a frivolous argument under Rehaif; (4) Petitioner’s controlled-substance offenses from St. Louis County, Missouri, for the delivery of a controlled substance and the sale of controlled substances, were properly included in his criminal history calculation, and counsel cannot be ineffective for the

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