Isaac Landours v. United States of America

CourtDistrict Court, D. New Mexico
DecidedJuly 10, 2026
Docket1:24-cv-00821
StatusUnknown

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

Bluebook
Isaac Landours v. United States of America, (D.N.M. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO

ISAAC LANDOURS,

Petitioner,

v. No. 1:24-cv-0821 KWR-JFR 1:22-cr-0451 KWR-JFR UNITED STATES OF AMERICA,

Respondent.

MEMORANDUM OPINION AND ORDER

This matter is before the Court on Petitioner Isaac Landours’ Motion to Vacate Federal Sentence Under 28 U.S.C. § 2255 (CV Doc. 1; CR Doc. 79) (Motion). Landours is incarcerated and proceeding pro se. He asks the Court to vacate his conviction based on four grounds of ineffective assistance of counsel. The United States responded. (CV Doc. 8). Having reviewed the record and applicable law, the Court will dismiss the Motion with prejudice and deny a certificate of appealability. BACKGROUND On November 15, 2021, Landours met with a confidential source (CS) and an undercover Special Agent with the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF). (CR Doc. 1) (Complaint). Through a controlled sale, Landours sold 56.04 grams of methamphetamine to the CS and undercover agent in exchange for $440. Id. On March 23, 2022, a grand jury returned a one-count Indictment against Landours, charging him with unlawfully, knowingly, and intentionally distributing 50 grams and more of methamphetamine in violation of 21 U.S.C. §§ 841 (a)(1) and (b)(1)(A). (CR Doc. 4) (Indictment). The United States Probation Office submitted a Presentence Investigation Report (PSR) on March 31, 2023. (CR Doc. 38). Landours entered a guilty plea pursuant to a Federal Rule of Criminal Procedure Rule 11(c)(1)(B) Plea Agreement on February 2, 2023. (CR Doc. 35) (Plea Agreement); (CV Doc. 8-4) (Plea Hearing Transcript). He appeared for sentencing on June 21, 2023 and July 27, 2023, however, both hearings were continued in order for the parties to submit additional briefing. On August 9, 2023, Landours was sentenced to a total term of 188 months

imprisonment and 4 years supervised release. (CR Doc. 58) (Judgment). Landours appealed his conviction. U.S. v. Landours, No. 23-2131, 2024 WL 687715 (8th Cir. 2024). He argued the district court erred in finding that: (1) a state conditional discharge was a conviction for purposes of calculating his criminal history; and (2) he was subject to a career offender enhancement. Id. The Eighth Circuit dismissed the appeal because it was barred by the appellate waiver in Landour’s Plea Agreement. Id. On August 16, 2024, Landours filed the instant Motion To Vacate, Set Aside, or Correct Sentence Under 28 U.S.C. § 2255 seeking to vacate his conviction and sentence. (CV Doc. 1; CR Doc. 79). The Motion asserts four grounds of ineffective assistance of counsel: (Claim 1): Counsel failed to argue that the prosecutor intentionally omitted a portion of the New Mexico conditional discharge statute, which resulted in him being improperly classified as a career offender;

(Claim 2): Counsel was “continuously tardy with her filings,” which prevented the Court from reviewing briefs;

(Claim 3): Counsel failed to argue against a two-point gun enhancement as there was no relationship between the gun and the drug offense; and

(Claim 4): Counsel should not have allowed him to sign a plea agreement that included an appellate waiver because there were “clear issues” that needed to be appealed.

(CV Doc. 1 at 4-8; CR Doc. 79 at 4-8). The Government filed a Response. (CV Doc. 8).

2 DISCUSSION A petition under 28 U.S.C. § 2255 attacks the legality of a federal prisoner’s detention. Bradshaw v. Story, 86 F.3d 164, 166 (10th Cir. 1996). A district court may grant relief under § 2255 if it determines “the judgment was rendered without jurisdiction, or that the sentence imposed was not authorized by law or otherwise open to collateral attack, or 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. Because Petitioner is proceeding pro se, the Court will liberally construe his pleadings. See Haines v. Kerner, 404 U.S. 519 (1972). This broad reading of a pro se litigant’s pleadings does not, however, relieve him of the burden of alleging sufficient facts upon which a legal claim may be based. Hall v. Bellmon, 935 F.2d 1106, 1110 (10th Cir. 1991). A. Ineffective Assistance of Counsel A successful ineffective assistance of counsel claim must meet the two-prong test set forth in Strickland v. Washington, 466 U.S. 668, 687 (1984). First, the petitioner must show “[c]ounsel’s performance was deficient” and contained “errors so serious that counsel was not

functioning as the ‘counsel’ guaranteed the defendant by the Sixth Amendment.” Id. at 688. In other words, the representation must fall below an objective standard of reasonableness based on prevailing professional norms. Id. at 687-88. The Court is required to “eliminate the distorting effects of hindsight” and “indulge a strong presumption that counsel acted reasonably.” Welch v. Workman, 639 F.3d 980, 1012 (10th Cir. 2011) (quotations omitted). The question to determine deficient performance “is whether [the] representation amounted to incompetence under ‘prevailing professional norms,’ not whether it deviated from best practices or most common custom.” Simpson v. Carpenter, 912 F.3d 542, 593 (10th Cir. 2018) (quoting Harrington v. 3 Richter, 562 U.S. 86, 105 (2011)); Williamson v. Ward, 110 F.3d 1508, 1514 (10th Cir. 1997) (“There is a strong presumption that counsel’s performance falls within the wide range of professional assistance, the defendant bears the burden of proving that counsel’s representation was unreasonable under prevailing professional norms and that the challenged action was not sound strategy.”) (citations omitted).

The second prong of Strickland requires the petitioner to affirmatively prove the deficient performance prejudiced the defense. Battenfield v. Gibson, 236 F.3d 1215, 1234 (10th Cir. 2001) (citing Strickland, 466 U.S. at 693). The movant must establish prejudice by showing “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. In the context of pleas, the petitioner must “show that there is a reasonable probability that, but for counsel’s errors, he would not have pleaded guilty and would have insisted on going to trial.” Hill v. Lockhart, 474 U.S. 52, 58-59 (1985). See also Lafler v. Cooper, 566 U.S. 156, 163 (2012) (“[A] defendant must show the outcome of the plea process would have been different with competent advice”). Courts may analyze either prong first and need only address one prong if the movant fails to make a sufficient

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Blackledge v. Allison
431 U.S. 63 (Supreme Court, 1977)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Hill v. Lockhart
474 U.S. 52 (Supreme Court, 1985)
Miller-El v. Cockrell
537 U.S. 322 (Supreme Court, 2003)
Bradshaw v. Story
86 F.3d 164 (Tenth Circuit, 1996)
Battenfield v. Gibson
236 F.3d 1215 (Tenth Circuit, 2001)
United States v. Black
44 F. App'x 368 (Tenth Circuit, 2002)
United States v. Romero-Gallardo
113 F. App'x 351 (Tenth Circuit, 2004)
United States v. Hamilton
510 F.3d 1209 (Tenth Circuit, 2007)
Tovar Mendoza v. Hatch
620 F.3d 1261 (Tenth Circuit, 2010)
Harrington v. Richter
131 S. Ct. 770 (Supreme Court, 2011)
Welch v. Workman
639 F.3d 980 (Tenth Circuit, 2011)
Seth Mason and Carl Peterson v. United States
719 F.2d 1485 (Tenth Circuit, 1983)
Lafler v. Cooper
132 S. Ct. 1376 (Supreme Court, 2012)
United States v. Reed
39 F.4th 1285 (Tenth Circuit, 2022)
Simpson v. Carpenter
912 F.3d 542 (Tenth Circuit, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
Isaac Landours v. United States of America, Counsel Stack Legal Research, https://law.counselstack.com/opinion/isaac-landours-v-united-states-of-america-nmd-2026.