Huntoon v. United States

CourtDistrict Court, D. Arizona
DecidedFebruary 10, 2022
Docket4:21-cv-00094
StatusUnknown

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

Bluebook
Huntoon v. United States, (D. Ariz. 2022).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Michael Huntoon, No. CV-21-00094-TUC-DCB No. CR-16-00046-TUC-DCB 10 Petitioner, ORDER 11 v.

12 United States of America,

13 Respondent. 14 15 Pending before this Court is Petitioner's "Motion to Vacate Sentence or Correct 16 Sentence," pursuant to 28 U.S.C. § 2255. ((Doc. 1 (Petition) in CV 21-94 TUC DCB); Doc. 17 188 (CR 16-46 TUC DCB)). The Court denies the motion and dismisses this action. 18 The Petitioner argues that his sentence is unconstitutional because the Court erred 19 in failing to suppress evidence obtained from an illegal search of Defendant’s laptop; erred 20 in admitting evidence under Rules 414 (similar crimes in child-molestation cases) and 404b 21 (other crimes, wrongs, and acts); erred in denying Defendant’s Motion for Disclosure 22 related to Torrential Downpour software and training; abused its discretion in failing to 23 grant a mistrial, and that there was cumulative error. 24 In the screening Order, the Court summarized the Petitioner’s claims as follows: 25 Count 1, ineffective assistance of counsel at trial; Count 2, denial of due process right to a 26 fair trial because the “404b cautionary instruction was “woefully inadequate”; Count 3, 27 Sixth Amendment speedy trial violation by the Government for “unduly delaying the 28 prosecution of his case”; Count 4, denial of due process right to a fair trial due to the 1 “admission and playing of Exhibit 20A, a redacted recorded jailhouse call between 2 Defendant and his wife; Count 5, Fourth Amendment violation because probable cause to 3 issue the State search warrant was founded on false material statements, therefore, the 4 search of the laptop was presumptively unreasonable; Count 6, Fifth and Fourteenth 5 Amendment due process violations because the State, without a court order, released the 6 laptop to the Government and it was searched without a warrant; Count 7, factual 7 innocence, and Count 8, ineffective assistance of counsel on appeal. (Order (Doc. 3) at 2- 8 3.) 9 For the reasons explained below, the Court denies these claims because they are 10 procedurally barred and entirely without merit. 11 A. Conviction and Sentence 12 The Petitioner Defendant was charged with distributing child pornography (Count 13 1); knowing access of child pornography (Count 2), and possession of child pornography 14 (Count 3). He was convicted by a jury of distributing and possessing child pornography. 15 On July 24, 2018, the Court sentenced the Defendant to concurrent sentences of 240 16 months on Counts 1 and 3, to run concurrent with the sentence to be imposed in a pending 17 state case. The Court sentenced Defendant to a lifetime of supervised release. On January 18 9, 2019, the Pinal County Superior Court imposed a 280-year sentence based on state 19 convictions for 10 counts of sexual exploitation with a minor. He is currently in Arizona 20 state custody, serving the 280-year sentence. 21 The Defendant appealed his convictions and sentences. On December 16, 2019, the 22 Ninth Circuit affirmed both. On March 23, 2020, the Supreme Court denied his petition for 23 certiorari. The Petitioner filed the habeas Petition, pursuant to 28 U.S.C. § 2255, on March 24 4, 2021. 25 26 27 28 1 2 B. 28 U.S.C. § 2255: Motion to Vacate or Correct Sentence 3 Title 28 of the United States Code, Section 2255 provides for collateral review of 4 Petitioner's conviction and sentence as follows: “A prisoner in custody under sentence of 5 a court established by Act of Congress claiming the right to be released upon the ground 6 that the sentence was imposed in violation of the Constitution or law of the United States, 7 or that the court was without jurisdiction to impose such sentence, or that the sentence was 8 in excess of the maximum authorized by law, or is otherwise subject to collateral attack, 9 may move the court which imposed the sentence to vacate, set aside or correct the 10 sentence.” 28 U.S.C. § 2255. 11 The Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA) instituted a 12 one-year limitations period for collateral attacks by federal and state prisoners. 28 U.S.C. 13 § 2255(f). As noted by the Government, the Petition is timely. An evidentiary hearing on 14 prisoner's Motion to Vacate Sentence is mandatory if the record does not affirmatively 15 manifest factual or legal invalidity of the prisoner's claims. United States v. Popoola, 881 16 F.2d 811, 812 (9th Cir. 1989). The Court may, however, summarily dismiss the Petition 17 without holding a hearing because the Petitioner fails to allege facts which, if true, would 18 entitle him to relief, and the Petition, files and record of the case conclusively show that he 19 is entitled to no relief. United States v. Howard, 381 F.3d 873, 877 (9th Cir. 2004). 20 Section 2255 was not intended to give prisoners another appeal; it may not be used 21 to overturn their convictions on grounds which could have been raised on direct appeal. 22 United States v. Dunham, 767 F.2d 1395, 1396 (9th Cir. 1985). Therefore, the Petitioner 23 may not relitigate in his 2255 Petition an issue he unsuccessfully raised on appeal. United 24 States v. Redd, 759 F.2d 699, 701 (9th Cir. 1985). This forecloses review pursuant to 28 25 U.S.C. § 2255 of the claims raised in Counts 2, 5 and 6. On direct appeal, the Defendant 26 challenged the legitimacy of the warrant and the admission under Rule 414 of the prior 27 child molestation conviction and admission of evidence under Rule 404b of prior charges 28 of possession of child pornography. He lost on both arguments. The appellate court also 1 rejected his argument challenging the sufficiency of the Court’s 404b cautionary 2 instruction. United States v. Huntoon, 796 Fed. Appx. 362 (9th Cir. 2019). Procedurally, 3 these claims cannot be relitigated on habeas review. 4 The remainder of the claims raised in Counts 2 through 7 are procedurally barred 5 because they could have been raised at trial or on direct appeal from the conviction, but 6 were not raised. They cannot be brought in a § 2255 proceeding unless the defendant can 7 show cause for the procedural default and prejudice arising from the failure to raise them. 8 United States v. Frady, 456 U.S. 152, 167-69 (1982); McCleskey v. Zant, 499 U.S. 467, 9 493-495 (1991); Parks v. United States, 832F.2d 1244, 1245-46 (11th Cir. 1987). "[A] 10 procedural default of even a constitutional issue will bar review under § 2255, unless the 11 defendant can meet the cause and prejudice test." Campino v. United States, 968 F.2d 187, 12 189-90 (2d Cir. 1992).

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