Hillard v. USA-2255

CourtDistrict Court, D. Maryland
DecidedMarch 23, 2020
Docket1:19-cv-02326
StatusUnknown

This text of Hillard v. USA-2255 (Hillard v. USA-2255) is published on Counsel Stack Legal Research, covering District Court, D. Maryland primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hillard v. USA-2255, (D. Md. 2020).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND

NATHANIEL HILLARD, a/k/a “Boo Boo,” Petitioner, Criminal No. ELH-17-0191 v. Related Civil No. ELH-19-2326

UNITED STATES OF AMERICA, Respondent.

MEMORANDUM OPINION

Nathaniel Hillard, the self-represented Petitioner, has filed a motion under 28 U.S.C. § 2255 (ECF 221, the “Petition”), seeking to vacate, set aside, or correct his sentence.1 The government opposes the Petition. ECF 241. Although Petitioner has since corresponded with the Court (ECF 243; ECF 254), he has not replied to the opposition. No hearing is necessary to resolve the Petition. For the reasons that follow, I shall deny the Petition. I. Factual and Procedural Background Hillard and three others were charged in a Superseding Indictment on July 11, 2017. ECF 63. Of relevance here, Hillard was charged in Count One with conspiracy to distribute and possess with the intent to distribute heroin, in violation of 21 U.S.C. § 846, and he was charged in Count Five with discharging a firearm resulting in death, during and in relation to a drug trafficking

1 Hillard was sentenced on May 21, 2018, and did not appeal, pursuant to the waiver of appellate rights in his Plea Agreement. The Petition was not filed until August 12, 2019. Hillard claims that he was unable to timely file his Petition “[d]ue to frequent institutional lock downs . . . .” ECF 221 at 10. His contention is supported by exhibits. See ECF 221 at 20, 21. The government does not seek dismissal under 28 U.S.C. § 2255(f). Therefore, I have not addressed the issue of timeliness. crime, in violation of 18 U.S.C. §§ 924(c), (j). The § 846 conspiracy offense served as the predicate crime for the § 924(c) offense. See ECF 63.2 Among other things, on March 17, 2017, investigators intercepted a call between Hillard and a co-conspirator, capturing in real time the murder of Donya Rigby, who sometimes acted as a “lookout” for the drug trafficking organization (“DTO”). Apparently, his performance was

regarded as unsatisfactory, and he displeased members of the DTO. ECF 119 at 4-5. In the intercepted call, Hillard was heard alerting a co-conspirator to Rigby’s presence, and he provided instruction as to the murder itself. Id. at 5. On January 16, 2018, Hillard entered a plea of guilty to both charges, pursuant to a Plea Agreement. See ECF 118; ECF 119 (Plea Agreement). In the Plea Agreement, the parties agreed that Hillard qualified as a career offender for the purpose of the drug conspiracy. They also agreed that he participated in a murder during the drug offense. ECF 119, ¶¶ 6(a), (b)(i). Therefore, the parties recognized that the murder cross-reference would ultimately decide Hillard’s base offense level. Paragraph 6(b)(ii) of the Plea Agreement (ECF 119) stated:

Further, the parties stipulate and agree that because the defendant knowingly participated in a first-degree murder in furtherance of the drug trafficking conspiracy, the defendant’s base offense level for the drug trafficking conspiracy is 43, pursuant to U.S.S.G. § 2D1.1(d)(1) and U.S.S.G. § 2A1.1.

Under the Plea Agreement, the government agreed to recommend a “reasonable sentence,” based on 18 U.S.C. § 3553(a) and the Sentencing Guidelines. ECF 119, ¶ 9. The Presentence Report (ECF 143, “PSR”) calculated Hillard’s advisory sentencing guidelines (“Guidelines” or “U.S.S.G.”), consistent with the Plea Agreement. The PSR concluded that Hillard was a Career Offender based on two prior Maryland convictions for armed robbery.

2 In view of the gravity of the charges, Hillard had two court-appointed attorneys. See ECF 143, ¶¶ 20, 27, 31. However, the murder cross-reference controlled the offense level, because it resulted in a higher base offense level. See id. ¶¶ 14, 20. Thus, as contemplated in the Plea Agreement, Hillard’s base offense level was 43. Id. ¶ 14. Because Hillard was a career offender, he had a Criminal History category of VI. Id. ¶ 35; see also id. ¶¶ 27, 31. Even if Hillard were not a career offender, however, he fell into a Criminal

History category of VI, because he had 13 criminal history points. Id. ¶ 34.3 Sentencing was conducted on May 21, 2018. ECF 157. During the hearing, the Court reiterated that the murder cross-reference—not Hillard’s Career Offender status—determined his base offense level. The Court said, ECF 230 at 6: Under the plea agreement, the offense level was increased to 37 because the defendant qualified as a career offender under [U.S.S.G. §] 4B1.1(b)(1). The parties also stipulated in the plea agreement that because the defendant knowingly participated in a first-degree murder in furtherance of the drug trafficking conspiracy, the offense level increases to 43 under [U.S.S.G. §] 2D1.1(d)(1) and 2A1.1.

Further, the Court observed that Hillard’s Criminal History category was the same, with or without Career Offender status. It said, id. at 11-12: When you add up the points, they result in a criminal history subscore of 11 points. The defendant committed this offense while under . . . a criminal justice sentence for the armed robbery in the case that is referenced in Paragraph 31 [of the PSR]. So two more points are added under 4A1.1(d). That adds up to 13 criminal history points. That adds up to a criminal history category of VI, which is the worst that you can have. And that’s without being a career offender. Even if he is a career offender, as I believe he is, it’s a VI. So either way, it doesn’t change. His criminal history category is VI.

Hillard’s counsel agreed that his two prior armed robberies qualified as predicate offenses for purposes of the Career Offender designation. Id. at 11. And, his lawyer added, id.: “I would

3 The underlying case was Hillard’s second federal offense. In 2004, he was convicted of possession of a firearm by a convicted felon in Case WDQ-04-035. Judge William D. Quarles, Jr. sentenced him to a term of 57 months’ imprisonment. just note in passing that even if Mr. Hillard was not a career offender, the guidelines wouldn’t change.” The Court sentenced Hillard to 300 months for the drug conspiracy and to a consecutive term of 120 months for the § 924(c) offense, resulting in a total term of imprisonment of 420 months. See ECF 158 (Judgment). Hillard did not appeal. Instead, he filed this Petition.

II. Discussion A. Section 2255(a) of Title 28 of the United States Code provides relief to a prisoner in federal custody only on specific grounds: that the sentence was imposed in violation of the Constitution or laws of the United States; that the court was without jurisdiction to impose such a sentence; that the sentence was in excess of the maximum authorized by law; or that the sentence is otherwise subject to collateral attack. See Hill v. United States, 368 U.S. 424, 426-27 (1962) (citing 28 U.S.C. § 2255); United States v. Hodge, 902 F.3d 420, 426 (4th Cir. 2018); United States v. Middleton, 883 F.3d 485 (4th Cir. 2018); United States v. Newbold, 791 F.3d 455, 459 (4th Cir.

2015); United States v. Pettiford, 612 F.3d 270, 277 (4th Cir. 2010). Pursuant to 28 U.S.C.

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Hillard v. USA-2255, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hillard-v-usa-2255-mdd-2020.