Hamilton v. United States

CourtDistrict Court, D. Idaho
DecidedMay 5, 2021
Docket1:20-cv-00359
StatusUnknown

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

Bluebook
Hamilton v. United States, (D. Idaho 2021).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF IDAHO VAUDENCIA CEBALLOS HAMILTON, Case No. 1:20-cv-00359-DCN Petitioner, 1:18-cr-00086-DCN

vs. MEMORANDUM DECISION AND ORDER UNITED STATES OF AMERICA,

Respondent.

I. INTRODUCTION Pending before the Court in the above entitled matter is Petitioner Vaudencia Cabellos Hamilton’s Motion to Vacate, Set Aside, or Correct Sentence under § 2255 (Dkt. 1).1 The Government filed a Response to Hamilton’s Motion. Hamilton did not file a reply and the time for doing so has now passed. The matter is now ripe for the Court’s review. II. BACKGROUND On March 13, 2018, a federal grand jury returned an Indictment charging Hamilton with Possession with Intent to Distribute Methamphetamine in violation of 21 U.S.C. § 841(a)(1) and (b)(1)(a) (Count 1), and Possession with Intent to Distribute Fentanyl in violation of 21 U.S.C. § 841(a)(1) and (b)(1)(c) (Count 2), CR-86, Dkt. 12. On July 11, 2018, a federal grand jury returned a Superseding Indictment charging Hamilton with an additional crime, Conspiracy to Distribute Fentanyl and Methamphetamine Resulting in

1 In this Order, “CR-86” is used when citing to Hamilton’s criminal case record in 1:18-cr-00086-DCN. All other docket citations are to the record in the instant civil case. Hamilton also filed her Motion to Vacate in her criminal case. CR-86, Dkt. 70. Serious Bodily Injury and Death in violation of 21 U.S.C. §§ 841(a)(1), (b)(1)(C) and 846 (Count 3). CR-86, Dkt. 21. The punishment for distribution of Fentanyl and Methamphetamine Resulting in Serious Bodily Injury and Death mandates a minimum

sentence of twenty years, while the mere possession with intent to distribute fentanyl or methamphetamine permits a sentence of not more than twenty years. Compare 21 U.S.C. § 21 U.S.C. 841(a)(1) with 21 U.S.C. § 841(b)(1)(C). On February 2, 2019, Hamilton entered into a plea agreement with the Government. Id., Dkt. 39. On March 11, 2019, Hamilton pleaded guilty to Count 3 of the Superseding

Indictment, Conspiracy to Distribute Fentanyl and Methamphetamine Resulting in Serious Bodily Injury and Death. Id., Dkt. 41. The Government moved to dismiss Counts 1 and 2 of the Superseding Indictment by oral motion. Id., Dkt. 50. On June 12, 2019, this Court dismissed Counts 1 and 2 of the Superseding Indictment, and sentenced Hamilton to twenty years of imprisonment and five years of supervised release. Id.

Hamilton immediately appealed the Court’s judgment. Id., Dkt. 53. The Ninth Circuit dismissed the appeal on June 9, 2020. Id., Dkt. 68. On July 17, 2020, Hamilton filed the pending petition, moving to vacate, set aside, or correct her sentence pursuant to 28 U.S.C. § 2255. III. ANALYSIS

A. Motion to Vacate (Dkt. 2); CR-281 (Dkt. 70) Title 28 U.S.C. § 2255 provides four grounds under which a federal court may grant relief to a federal prisoner who challenges the imposition or length of his or her incarceration: (1) “that the sentence was imposed in violation of the Constitution or laws of the United States;” (2) “that the court was without jurisdiction to impose such sentence;” (3) “that the sentence was in excess of the maximum authorized by law;” or (4) “that the sentence is otherwise subject to collateral attack[.]” 28 U.S.C. § 2255(a). Relief under

§ 2255 is afforded “[i]f the court finds that . . . there has been such a denial or infringement of the constitutional rights of the prisoner as to render the judgment vulnerable to collateral attack.” 28 U.S.C. § 2255(b). Hamilton suggests she is entitled to relief under § 2255 due to ineffective assistance of counsel. 1. Timeliness of Petition

Under the applicable statute of limitations, a § 2255 motion must be brought within one year after a judgment of conviction becomes final unless the motion has been statutorily tolled according to 28 U.S.C. § 2255(f)(2)–(4). A judgment of conviction becomes final when it “has been rendered, the availability of appeal exhausted, and the time for a petition for certiorari elapsed or a petition for certiorari denied.” United States

v. Schwartz, 274 F.3d 1220, 1223 (9th Cir. 2001). Hamilton’s § 2255 petition was filed on July 17, 2020—well before her appeal rights were exhausted on approximately September 9, 2020 —and is thus timely. 2 2. Evidentiary Hearing and Request for Counsel Under § 2255, “a district court must grant a hearing to determine the validity of a

2 Hamilton’s appeal to the Ninth Circuit was dismissed on June 9, 2020. CR-86, Dkt. 69. For purposes of postconviction relief, Hamilton’s judgment became “final” when the time for filing a petition for certiorari expired approximately 90 days after the Ninth Circuit issued its judgment. Clay v. United States, 537 U.S. 522, 525 (2003) (“For purpose of starting the clock on § 2255’s one-year limitation period . . . a judgment of conviction becomes final when the time expires for filing a petition of certiorari contesting the appellate court’s affirmation of the conviction.”); see also Sup. Ct. R. 13 . petition,” “‘[u]nless the motions and the files and records of the case conclusively show that the prisoner is entitled to no relief.’” United States v. Baylock, 20 F.3d 1458, 1465 (9th Cir. 1994) (emphasis in original) (quoting § 2255). In determining whether a § 2255 motion

requires a hearing, “[t]he standard essentially is whether the movant has made specific factual allegations that, if true, state a claim on which relief could be granted.” United States v. Withers, 638 F.3d 1055, 1062 (9th Cir. 2011) (quotation marks omitted) (alteration in original). A district court may dismiss a § 2255 motion based on a facial review of the record “only if the allegations in the motion, when viewed against the record, do not give

rise to a claim for relief or are ‘palpably incredible or patently frivolous.’” Id. at 1062–63 (quoting United States v. Schaflander, 743 F.2d 714, 717 (9th Cir. 1984)). Conclusory statements in a § 2255 motion are insufficient to require a hearing. United States v. Hearst, 638 F.2d 1190, 1194 (9th Cir. 1980). For the reasons explained below, the claims raised in Hamilton’s § 2255 motion are

conclusory and/or do not give rise to a claim for relief. The Court accordingly finds an evidentiary hearing is not necessary and will decide the motion on a facial review of the record.

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Hamilton v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hamilton-v-united-states-idd-2021.