James Calvin Hennings v. United States of America

CourtDistrict Court, W.D. Tennessee
DecidedJune 24, 2026
Docket1:25-cv-01299
StatusUnknown

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

Bluebook
James Calvin Hennings v. United States of America, (W.D. Tenn. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TENNESSEE EASTERN DIVISION ______________________________________________________________________________

JAMES CALVIN HENNINGS, ) ) Movant, ) v. ) No. 1:25-cv-01299-STA-jay ) UNITED STATES OF AMERICA, ) ) Respondent. ) ______________________________________________________________________________

ORDER DENYING MOVANT’S MOTION TO VACATE, SET ASIDE, OR CORRECT SENTENCE PURSUANT TO 28 U.S.C. § 2255 ORDER OF DISMISSAL ORDER ON APPEAL ISSUES ______________________________________________________________________________ Before the Court is Movant James Calvin Hennings’s Motion to Vacate, Set Aside, or Correct Sentence Pursuant to 28 U.S.C. § 2255 (ECF No. 1), as amended (ECF No. 4) on January 20, 2026 (“the Amended § 2255 Motion”). The government has filed an Answer (ECF No. 12) and an Amended Answer (ECF No. 19), denying the allegations of the Hennings’ Amended § 2255 Motion. For the reasons set forth below, the Court DENIES Hennings’s Amended § 2255 Motion. BACKGROUND Hennings has two criminal judgments against him in this District: a conviction for conspiracy to possess with the intent to distribute 50 grams or more of actual methamphetamine (case no. 1:23-cr-10044-STA) and possession of contraband in a prison in violation of 18 U.S.C. § 1791 (no. 1:25-10018-STA). The Court held sentencing hearings and entered separate judgments in both cases on July 8, 2025. Hennings appealed the judgment against him in 1:23-cr-10044. See Notice of Appeal, July 15, 2025 (ECF No. 144, no. 1:23-cr-10044). Hennings’ Amended § 2255 Motion challenges his conviction in his other case for possessing contraband in a prison, case no. 1:25-10018. Amended § 2255 Motion 1 (ECF No. 4) (stating that Hennings’s offense was “possession of contraband in prison by a federal inmate,” his sentence was 10 months’ incarceration, and that his case number was 1:25-cr-10018-STA). Hennings did not appeal his conviction in case no. 1:25-cr-10018. In fact, the whole basis for his

motion to vacate the conviction is Hennings’s claim that trial counsel was ineffective because she failed to follow Hennings’ instructions to appeal the Court’s judgment in case no. 1:25-cr-10018. By way of background, the government initiated its prosecution against Hennings in case no. 1:25-cr-10018 through an information. The information accused Hennings of illegally possessing a phone while he was an inmate in the custody of the Shelby County Division of Corrections in Memphis, Tennessee. Hennings waived his right to an indictment and consented to the prosecution against him on the basis of the information. Waiver of Indictment, Mar. 25, 2025 (ECF No. 3, no. 1:25-cr-10018). Hennings entered a guilty plea on the charge at a hearing before the undersigned on March 25, 2025. In anticipation of sentencing, the United States Probation Office prepared the presentence

report (the “PSR”) (ECF No. 9, no. 1:25-cr-10018). According to the PSR, the statutory maximum sentence for Hennings’s possessory crime was 1 year of imprisonment. The PSR calculated a total adjusted offense level of 4 and a criminal history category of V. Id. at ¶ 71. Based on an offense level of 4 and a criminal history category of V, the Guidelines range for Hennings’s offense was 4 months to 10 months of incarceration. Hennings through appointed counsel filed objections to the PSR (ECF No. 6, 7) as well as a position paper on the PSR (ECF No. 8). Hennings had no objections to the facts stated in the PSR or the PSR’s calculations of the appropriate Guidelines range for his offense. Hennings requested a sentence of 4 months and asked the Court to make his sentence run concurrently with any sentence imposed against him in case no. 1:23-cr-10044. The Court held a sentencing hearing on July 8, 2025. After hearing argument from counsel and allocution from Hennings, the Court adopted the findings of the PSR and analyzed the sentencing factors set forth in 18 U.S.C. § 3553(a). The Court sentenced Hennings to 10 months, to be served consecutive to his sentence in case no. 1:23-cr-10044, and one year of supervised

release. Judgment (ECF No. 13, no. 1:25-cr-10018) was entered the same day. Hennings did not appeal. Hennings remains in the custody of the Bureau of Prisons, BOP register number 74442- 510. The BOP projects his release date as May 10, 2047. Hennings raises just one issue in his Amended § 2255 Motion. Ground 1 alleges that Hennings’s trial counsel was ineffective for failing to file a notice of appeal when Hennings asked her to do so. Hennings admits trial counsel advised him about an appeal and took the position he had no grounds for an appeal in case no. 1:25-cr-10018. The government has responded in opposition to Hennings’s Amended § 2255 Motion.1 As part of its Amended Answer, the government submitted an affidavit from Hennings’ trial attorney, Assistant Federal Public Defender Dianne M. Smothers, Esq. (ECF No. 19-1). Ms. Smothers stated

in her affidavit that she acted as trial counsel for Hennings in both of the criminal cases against him. According to Ms. Smothers, she met with Hennings after his sentencing hearing in a holding cell area adjacent to the courtroom. Ms. Smothers advised him that there were no objections to the PSR’s Guidelines calculation for his sentence in case no. 1:25-cr-10018, and so Hennings had no grounds to appeal his sentence in that case. In Ms. Smothers’ opinion, the sentence imposed was

1 The United States of America filed an initial Answer to the Amended § 2255 Motion (ECF No. 12) on February 19, 2026. The government argued that the Court should dismiss the Amended § 2255 Motion because Hennings’ criminal case was still on direct appeal. But the Court ordered the government to file an amended response because the government’s pleading did not address the fact that Hennings was challenging his conviction in case no. 1:25-10018-STA, not in no. 1:23-cr-10044. within the Guidelines range and the Court had exercised its discretion to make the sentences in Hennings’s two cases run consecutively to each other. The affidavit goes on to state that Ms. Smothers wrote to Hennings on July 10, 2025, two days after the sentencing hearing. Ms. Smothers attached her correspondence to her affidavit. Ms.

Smothers’s letter dated July 10, 2025, enclosed copies of the judgments against Hennings in each of his criminal cases. Ms. Smothers reminded Hennings of the appeal waiver in case no. 1:23-cr- 10044 and opined that the waiver would likely block relief on appeal. Ms. Smothers’s letter also stated that the sentence in case no. 1:25-cr-10018 was within the Guidelines range, the defense had raised no objections to the calculation of the range, and therefore, “no issues existed which could be raised on direct appeal.” Ms. Smothers’s affidavit states that on Friday, July 11, 2025, Hennings called her and informed her he wanted to file an appeal in case no. 1:23-cr-10044. Ms. Smothers told Hennings she would file the appeal and reminded him about the appeal waiver in his plea agreement in that case. According to Ms. Smothers’s affidavit, Hennings told her during the phone conversation that

he only wanted to appeal the judgment in case no. 1:23-10044. Ms. Smothers made notes about the phone conversation and specifically noted that Hennings had only directed her to appeal the conviction in case no. 1:23-10044. Ms.

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