George v. United States of America (INMATE 3)

CourtDistrict Court, M.D. Alabama
DecidedAugust 4, 2020
Docket2:17-cv-00337
StatusUnknown

This text of George v. United States of America (INMATE 3) (George v. United States of America (INMATE 3)) is published on Counsel Stack Legal Research, covering District Court, M.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
George v. United States of America (INMATE 3), (M.D. Ala. 2020).

Opinion

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

WILLIAM RAY GEORGE, ) ) Petitioner, ) ) CIVIL ACTION NO. v. ) 2:17-CV-337-WKW ) [WO] UNITED STATES OF AMERICA, ) ) Respondent. )

RECOMMENDATION OF THE MAGISTRATE JUDGE William Ray George is before the court on his motion to vacate, set aside, or correct sentence under 28 U.S.C. § 2255. CIV Doc. 1.1 For the reasons that follow, the court finds George’s § 2255 motion should be denied without an evidentiary hearing and dismissed with prejudice. I. BACKGROUND On August 31, 2015, George pled guilty to an information charging him with receipt of child pornography in violation of 18 U.S.C. § 2252A(a)(2). CR Doc. 16. George’s plea was entered under a plea agreement containing a waiver of his right to appeal or collaterally attack his sentence except on grounds of ineffective assistance of counsel or prosecutorial

1 References to document numbers assigned by the Clerk in the instant civil action, Civil Action No. 2:17-CV-337-WKW, are designated as “CIV Doc.” References to document numbers assigned by the Clerk in the underlying criminal case, Case No. 2:15-CR-344-WKW, are designated as “CR Doc.” Pinpoint citations are to the page of the electronically filed document in the court’s CM/ECF filing system, which may not correspond to pagination on the hard copy of the document presented for filing. misconduct. CIV Doc. 9-4 at 8. On May 11, 2016, the district court sentenced George to 84 months in prison.2 CIV Doc. 9-7. George did not appeal. On May 18, 2017, George, proceeding pro se, filed this § 2255 motion asserting the

following claims: 1. His sentence of imprisonment violates the Eighth Amendment prohibition against cruel and unusual punishment because his conduct resulted from his mental illness—specifically, Asperger’s syndrome.

2. The district court based his sentence on inaccurate information about the BOP’s ability to provide him with adequate treatment for his mental illness.

3. The government engaged in misconduct by allowing the district court to believe he would receive adequate treatment for his mental illness in prison.

4. His counsel was ineffective for failing to discover or argue that the BOP is incapable of providing him with adequate treatment for his mental illness.

CIV Doc. 1 at 4–8; CIV Doc. 1-1 at 1–5. II. DISCUSSION A. General Standard of Review Because collateral review is not a substitute for direct appeal, the grounds for collateral attack on final judgments under 28 U.S.C. § 2255 are limited. A prisoner is entitled to relief under § 2255 if the court imposed a sentence that (1) violated the Constitution or laws of the United States, (2) exceeded its jurisdiction, (3) exceeded the

2 George’s 84-month sentence resulted from a downward variance granted by the district court from George’s calculated Sentencing Guidelines range of 121 to 151 months. See CIV Doc. 9-7 at 47–57.

2 maximum authorized by law, or (4) is otherwise subject to collateral attack. 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 constitutional 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 justice.’” Lynn v. United States, 365 F.3d 1225, 1232 (11th Cir. 2004) (citations omitted). B. Standard for Reviewing Claims of Ineffective Assistance of Counsel

A claim of ineffective assistance of counsel must be evaluated against the two-part test announced in Strickland v. Washington, 466 U.S. 668 (1984). First, a petitioner must show that “counsel’s representation fell below an objective standard of reasonableness.” Id. at 689. Second, the petitioner must show that “there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been

different.” Id. at 694. See Chandler v. United States, 218 F.3d 1305, 1313 (11th Cir. 2000). Scrutiny of counsel’s performance is “highly deferential,” and the court indulges a “strong presumption” that counsel’s performance was reasonable. Chandler, 218 F.3d at 1314 (internal quotation marks omitted). The court will “avoid second-guessing counsel’s performance: It does not follow that any counsel who takes an approach [the court] would

not have chosen is guilty of rendering ineffective assistance.” Id. (internal quotation marks and brackets omitted). “Given the strong presumption in favor of competence, the

3 petitioner’s burden of persuasion—though the presumption is not insurmountable—is a heavy one.” Id. As noted, under the prejudice component of Strickland, a petitioner must show that

“there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different” Strickland, 466 U.S. at 694. A “reasonable probability is a probability sufficient to undermine confidence in the outcome.” Id. The prejudice prong does not focus only on the outcome; rather, to establish prejudice, the petitioner must show that counsel’s deficient representation rendered the result of the trial

fundamentally unfair or unreliable. See Lockhart v. Fretwell, 506 U.S. 364, 369 (1993) (“[A]n analysis focusing solely on mere outcome determination, without attention to whether the result of the proceeding was fundamentally unfair or unreliable, is defective.”). “Unreliability or unfairness does not result if the ineffectiveness of counsel does not deprive the defendant of any substantive or procedural right to which the law entitles him.”

Id. at 372. Unless a petitioner satisfies the showings required on both prongs of the Strickland inquiry, relief should be denied. Strickland, 466 U.S. at 687. Once a court decides that one of the requisite showings has not been made, it need not decide whether the other one has been. Id. at 697; Duren v. Hopper, 161 F.3d 655, 660 (11th Cir. 1998).

C. Claims Regarding Sentence 1. Eighth Amendment Claim

4 George claims that his sentence of imprisonment violates the Eighth Amendment prohibition against cruel and unusual punishment because, he says, his conduct resulted from his mental illness—specifically, his Asperger’s syndrome, a form of high-functioning

autism.3 CIV Doc. 1 at 4; CIV Doc. 1-1 at 1. In this regard, George argues that he was punished for a “status crime” (his mental illness), which is unconstitutional under the Eighth Amendment. See CIV Doc. 1-1 at 1. In support of this argument, George cites the district court’s statement at sentencing that his case involved “an autism person with a sex offender problem” as opposed to “a sex offender with autism problem.” See CIV Doc. 9-

7 at 51–52.

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George v. United States of America (INMATE 3), Counsel Stack Legal Research, https://law.counselstack.com/opinion/george-v-united-states-of-america-inmate-3-almd-2020.