James Baker v. United States

CourtCourt of Appeals for the Sixth Circuit
DecidedMay 20, 2021
Docket19-6025
StatusUnpublished

This text of James Baker v. United States (James Baker v. United States) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
James Baker v. United States, (6th Cir. 2021).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 21a0248n.06

No. 19-6025

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED JAMES BAKER, ) May 20, 2021 ) DEBORAH S. HUNT, Clerk Petitioner-Appellant, ) ) v. ) ON APPEAL FROM THE ) UNITED STATES DISTRICT UNITED STATES OF AMERICA, ) COURT FOR THE WESTERN ) DISTRICT OF TENNESSEE Respondent-Appellee. ) ) )

BEFORE: ROGERS, WHITE, and MURPHY, Circuit Judges.

ROGERS, Circuit Judge. In this suit for post-conviction relief under 28 U.S.C. § 2255, the

district court denied relief solely on a ground that the government now concedes was erroneous.

The government urges us to affirm on one of several alternative grounds. These grounds have not

been addressed by the district court, and such consideration would be valuable in our examination

of the government’s alternative arguments. We therefore decline to rule on the alternative grounds

on this appeal, but instead remand for initial consideration by the district court. This panel

unanimously agrees that oral argument is not needed. See Fed. R. App. P. 34(a).

In April 2013, Baker was convicted of three offenses: (1) being a felon in possession of a

firearm in violation of 18 U.S.C. § 922(g)(1), (2) possession with intent to distribute cocaine in

violation of 21 U.S.C. § 841(a)(1), and (3) use of a firearm in the commission of a felony in

violation of 18 U.S.C. § 924(c). The district court sentenced him to 276 months’ imprisonment:

216 months for the Section 922(g)(1) and drug-possession charges, to be served concurrently, and No. 19-6025, Baker v. United States

a mandatory 60 months for the Section 924(c) charge, to be served consecutively. We affirmed

Baker’s conviction and sentence on direct appeal. United States v. Baker, 562 F. App’x 447, 457

(6th Cir. 2014), cert. denied 573 U.S. 939 (2014).

In April 2015, Baker filed a pro se motion under 28 U.S.C. § 2255 to vacate his sentence,

asserting several ineffective-assistance-of-counsel claims. The government opposed the motion.

In later pro se filings, Baker supplemented his § 2255 petition to add, among other claims, a claim

that his conviction is invalid in light of Rehaif v. United States, 139 S. Ct. 2191 (2019).

The district court denied the § 2255 motion, concluding in relevant part that “as for Rehaif,

the Supreme Court has yet to rule whether it applies retroactively.” We granted a certificate of

appealability (“COA”) with respect to Baker’s Rehaif claim and denied a COA as to all other

claims.

On appeal, both parties agree that Rehaif applies retroactively to cases on collateral review.

We accept the government’s concession on this issue, for the reasons we recently stated in Kelley

v. United States, No. 20-5448 (6th Cir. Feb. 5, 2021) (per curiam) (order):

The parties agree that the district court erred when it concluded that Rehaif was not retroactively applicable to cases on collateral review. In Rehaif, the Supreme Court held that, “in prosecutions under § 922(g) . . . the Government must prove that the defendant knows of his status as a person barred from possessing a firearm.” 139 S. Ct. at 2195. Similar to the Court’s decisions in Bailey v. United States, 516 U.S. 137 (1995), and Burrage v. United States, 571 U.S. 204 (2014), the Court in Rehaif interpreted a criminal statute to require proof of an additional element to convict a defendant. In Bailey, the Court held that, to convict a defendant under 18 U.S.C. § 924(c)(1) for “using” a firearm, the government must show “active employment of the firearm.” 516 U.S. at 144. The Court later ruled that, because Bailey held “that a substantive federal criminal statute does not reach certain conduct,” it was a substantive rule and thus applied retroactively to cases on collateral review. Bousley v. United States, 523 U.S. 614, 620 (1998). And in Burrage, the Court held that, to convict a defendant under 21 U.S.C. § 841(b)(1) for a drug crime in which “death or serious bodily injury results from the use of such substance,” the government must show that the use of the drug is a but-for cause of the death, rather than merely a contributing cause. 571 U.S. at 218-19. We have held that Burrage applies retroactively to cases on collateral review because it was a substantive rule

-2- No. 19-6025, Baker v. United States

that narrowed the scope of a criminal statute. Harrington v. Ormond, 900 F.3d 246, 249 (6th Cir. 2018). In Bailey, Burrage, and Rehaif, the Supreme Court interpreted a criminal statute to require proof of an additional element to convict a defendant. Thus, just as Bailey and Burrage announced new substantive rules that apply retroactively to cases on collateral review, so did Rehaif. See Schriro v. Summerlin, 542 U.S. 348, 354 (2004) (“A decision that modifies the elements of an offense is normally substantive rather than procedural. New elements alter the range of conduct the statute punishes, rendering some formerly unlawful conduct lawful or vice versa.”). Kelley, No. 20-5448, ECF No. 20-2 at 3-4.

Despite the parties’ agreement on the sole issue in this appeal, the government maintains

that we should affirm the district court because Baker procedurally defaulted his Rehaif claim by

failing to assert it at trial or on direct appeal, though Baker responds that the government forfeited

such an argument by not raising it below. The government contends that, even if Baker could

overcome procedural default, it should prevail on the merits because Baker has not demonstrated

that he is entitled to habeas relief on the grounds that the error had a “substantial and injurious

effect or influence in determining the jury’s verdict.” Brecht v. Abrahamson, 507 U.S. 619, 637-

38 (1993) (quoting Kotteakos v. United States, 328 U.S. 750, 776 (1946)). In the alternative, the

government contends that we can reject Baker’s challenge to his § 922(g) conviction on the basis

of the “concurrent sentencing doctrine.” See Dale v. Haeberlin, 878 F.2d 930, 935 n.3 (6th Cir.

1989).

Because the district court did not address the merits of the Rehaif claim or the government’s

alternative grounds for upholding Baker’s conviction, we leave it to the district court to decide

these issues in the first instance. Here, the district court rejected the Rehaif claim on its initial

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Related

Kotteakos v. United States
328 U.S. 750 (Supreme Court, 1946)
Brecht v. Abrahamson
507 U.S. 619 (Supreme Court, 1993)
Bailey v. United States
516 U.S. 137 (Supreme Court, 1995)
Bousley v. United States
523 U.S. 614 (Supreme Court, 1998)
Schriro v. Summerlin
542 U.S. 348 (Supreme Court, 2004)
Burrage v. United States
134 S. Ct. 881 (Supreme Court, 2014)
United States v. James Baker
562 F. App'x 447 (Sixth Circuit, 2014)
Kurt Harrington v. J. Ray Ormond
900 F.3d 246 (Sixth Circuit, 2018)
Rehaif v. United States
588 U.S. 225 (Supreme Court, 2019)

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