Harris v. United States

District Court, E.D. Missouri·Decided November 27, 2024·No. 1:22-cv-00049·Unknown

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI SOUTHEASTERN DIVISION

RASHIEK AMOND HARRIS, ) ) Petitioner, ) ) v. ) Case No. 1:22-cv-00049-SNLJ ) UNITED STATES OF AMERICA, ) ) Respondent. )

MEMORANDUM AND ORDER On April 18, 2022, Petitioner Rasheik Amond Harris (“Harris”) filed this Motion to Vacate, Set Aside or Correct Sentence pursuant to Title 28, United States Code, Section 2255. This Court then ordered the United States to show cause why the relief requested in Hudson’s motion should not be granted. Based on the reasons set forth below, this Court will dismiss Hudson’s claims as waived and procedurally barred or otherwise deny them without an evidentiary hearing because they fail as a matter of law. I. PROCEDURAL HISTORY On March 9, 2017, Sikeston Department of Public Safety Captain Andrew Cooper observed Rashiek Harris driving his girlfriend’s vehicle in Sikeston. Trial Tr., Vol. I, p. 86. Cooper had known Harris since he was a juvenile and was aware that Harris’s driver’s license was suspended. Trial Tr., Vol. I, p. 87. Cooper followed Harris briefly while waiting for confirmation from the dispatcher on Harris’s license status, and parked at the curb when Harris pulled into a driveway. Id. Cooper approached the driver’s door to speak with Harris and was followed shortly by other officers including Detective Mario Whitney. Trial Tr., Vol. I, p. 88) The officers confirmed that Harris’s license was suspended and Harris was asked to step out of the

vehicle. Id. When Harris went to get out of the vehicle, Detective Whitley observed a loaded revolver in the driver’s side door pocket of the vehicle. Trial Tr., Vol. I, p. 88, 98, 110. Harris’s girlfriend, who owned the vehicle, gave officers consent to search, and they located an amount of methamphetamine and a small amount of what they suspected to be crack cocaine. Trial Tr., Vol. I, p. 99, 105, 110, 114. The substance field tested for cocaine, but was later demonstrated to be heroin at the Crime Lab. Trial Tr., Vol. I, p. 100. Harris

initially denied knowing anything about the drugs, but ultimately admitted that the drugs were his during a videotaped interview. Trial Tr., Vol. I, p. 120-122. Harris was charged by Indictment on May 18, 2017, with one count of possession of fifty grams or more of a mixture or substance containing a detectable amount of methamphetamine in violation of Title 21, United States Code, Section 841(a)(1), and one

count of being a felon in possession of a firearm in violation of Title 18, United States Code, Section 922(g)(1). Doc. 1, 1:17-cr-00044-SNLJ. After losing pretrial motions, Harris proceeded to a jury trial on April 2nd and 3rd, 2018. Doc. 92, 96, 1:17-cr-00044-SNLJ. The jury found Harris guilty on both counts. Doc. 96, 1:17-cr-00044-SNLJ.

A presentence investigative report (“PSR”) was filed, which recommended that the base offense level was 24 based on 97.14 grams of a mixture or substance containing methamphetamine, .53 grams of heroin and 1.91 grams of fentanyl. PSR ¶ 18. Two levels were added due to Harris’s possession of the revolver in connection with the drugs. PSR ¶ 19. Harris received no adjustment for acceptance of responsibility. PSR ¶ 25. The total offense level was determined to be 26. PSR ¶ 26.

Harris’s criminal history is fairly extensive and included countable convictions for burglary 2nd degree (PSR ¶ 29), felony distribution of a controlled substance near a school (PSR ¶ 36), felony unlawful possession of a firearm (PSR ¶ 37), misdemeanor destruction of property (PSR ¶ 38), misdemeanor possession of drug paraphernalia (PSR ¶ 39), felony possession of a controlled substance in a jail (PSR ¶ 40), driving while license revoked (PSR ¶ 41), and misdemeanor theft of rented or leased property (PSR ¶ 42). With a total of

16 criminal history points, Harris was assigned a criminal history category of VI. PSR ¶ 45. With a total offense level of 26 and a criminal history category of VI, the advisory sentencing guidelines range was 120-150 months imprisonment. PSR ¶ 84 Harris was sentenced on July 3, 2018, and received a term of incarceration of 150 months on Count I, concurrent to 120 months on Count II, to be followed by concurrent

terms of supervised release. Doc. 108, 1:17-cr-00044-SNLJ. Harris appealed, alleging that the District Court had denied him a pretrial hearing on evidentiary issues, erred in admitting hearsay, erred in failing to instruct the jury properly, and erred in imposing a sentence at the top of the advisory guidelines range. United States v. Harris, 964 F.3d 718 (8th Cir. 2020). The Eighth Circuit Court of Appeals upheld the District Court, and Harris petitioned

for a Writ of Certiorari which was denied. Doc. 133, 134, 1:17-cr-00044-SNLJ. Harris then filed the instant motion under Title 28, United States Code, Section 2255, raising four grounds for relief. Doc. 1. II. LEGAL STANDARD A. Section 2255 Relief

“Section 2255 was intended to afford federal prisoners a remedy identical in scope to federal habeas corpus.” Sun Bear v. United States, 644 F.3d 700, 704 (8th Cir. 2011) (en banc) (quotation omitted). And like habeas corpus, this statutory remedy “does not encompass all claimed errors in conviction and sentencing.” Id. (quoting United States v. Addonizio, 442 U.S. 178, 185 (1979)). Under Section 2255(a), a petitioner may file a motion for post-conviction review on four specified grounds: “(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,’ and (4) that the sentence ‘is otherwise subject to collateral attack.’” Martin v. United States, 150 F. Supp. 3d. 1047, 1049 (W.D. Mo. 2015) (quoting Hill v. United States, 368 U.S. 424, 426-27 (1962)); See also R. GOVERNING §

2255 PROCEEDINGS 1. The petitioner bears the burden of proof as to each asserted ground for relief. Golinveaux v. United States, 915 F.3d 564, 567 (8th Cir. 2019) (citation omitted). B. Ineffective Assistance of Counsel In order to prevail on a theory of ineffective assistance of counsel, the Movant must demonstrate two separate things; that counsel’s representation fell below an objective

standard of reasonableness (was constitutionally deficient), and secondly that counsel’s deficient performance materially and adversely prejudiced the outcome of the case. Furnish v. United States of America, 252 F.3d 950, 951 (8th Cir. 2001). While counsel has a duty to make reasonable investigations and decisions, in determining whether counsel’s performance was deficient, the court should “indulge a strong presumption that counsel’s conduct falls within the wide range of reasonable professional assistance.” Collins v.

Dormire, 240 F.3d 724, 727 (8th Cir. 2001). In order to prove that counsel’s error was prejudicial, Movant must prove that “there is a reasonable probability that, but for counsel’s unprofessional errors, the results of the proceedings would have been different.” Strickland, 466 U.S. at 694. A reasonable probability has been described as “a probability sufficient to undermine confidence in the outcome.” Id. However, the reviewing court need not address the issue of counsel’s

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