Joel Aaron Waters v. United States of America

CourtDistrict Court, D. Idaho
DecidedJuly 1, 2026
Docket1:25-cv-00355
StatusUnknown

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

Bluebook
Joel Aaron Waters v. United States of America, (D. Idaho 2026).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF IDAHO JOEL AARON WATERS, Case No. 1:25-cv-00355-DCN Petitioner, 1:21-cr-00112-DCN-1

v. MEMORANDUM DECISION AND ORDER UNITED STATES OF AMERICA, Respondent.

I. INTRODUCTION Before the Court is Petitioner Joel Waters’ Motion to Vacate, Set Aside, or Correct Sentence pursuant to 28 U.S.C. § 2255. Dkt. 1; CR-112, Dkt. 105.1 The Government opposed Waters’ petition. Dkt. 12. Waters did not reply.2 Having reviewed the record and briefs, the Court finds the facts and legal arguments are adequately presented. In the interest of avoiding further delay, the Court will decide the Petition on the record and without oral argument. Dist. Idaho Loc. Civ. R. 7.1(d)(1)(B). For the reasons set forth below, the Court DENIES Waters’ Motion to Vacate, Set Aside, or Correct Sentence under 28 U.S.C. § 2255.

1 In this Order, “CR-112” is used when citing to the criminal record in Case No. 1:21-cr-00112-DCN-1. All other docket citations are to the instant civil case. 2 Waters claimed he did not initially receive notice of the Government’s response to his petition. Dkt. 13. The Government subsequently re-served its response. Dkt. 14. Waters has not notified the Court whether he received the second notice. Regardless, the Court need not await a reply from Waters because the questions presented would not benefit from additional briefing. II. BACKGROUND In April 2021, a federal grand jury indicted Waters on two counts: (1) Interstate Stalking, and (2) Cyberstalking. CR-112, Dkt. 1. The Indictment included special

allegations that these crimes were committed while Waters was subject to a protection order issued in Wallowa County, Oregon. Id. at 2. During plea negotiations, the federal prosecutor discussed (via email) with an Oregon state prosecutor the possible state criminal charges and the penalties Waters might face in both jurisdictions. Dkt. 1-3, at 4. The Oregon state prosecutor stated she could not

“give a recommendation on sentenc[ing]” but opined that Waters’ federal and Oregon state “sentences should run concurrently.” Id. Waters later entered a guilty plea, and the Government dismissed Count 2 and recommended a 60-month sentence. CR-112, Dkt. 82. As part of his plea agreement, Waters “waive[d] any right to appeal or collaterally attack [his] plea, conviction, judgment, and sentence.” Id. at 10. The plea agreement stated the

waiver does not preclude Waters from filing an ineffective assistance of counsel claim. Id. at 11. At the change of plea hearing, United States Magistrate Judge Debora K. Grasham warned Waters that his “federal sentence may run consecutive or back-to-back to any sentence that [he] might receive in any state proceedings.” CR-112, Dkt. 106, at 11:19–22.

Waters also acknowledged his attorney’s prediction of his sentence was “just her best guess and is nonbinding.” Id. at 25:5–9. This Court later sentenced Waters to 60 months imprisonment and added 30 days for contempt of court. CR-112, Dkt. 97. His federal judgment is silent regarding whether any future state sentences will run concurrently with his federal sentence. Id. Waters claims the email exchange between the Oregon state prosecutor and the federal prosecutor constituted a plea agreement (or what he calls a “global resolution”)

between himself and the Wallowa County prosecutor’s office. Dkt. 1, at 4. According to Waters, the global resolution provided that any Oregon state sentence is supposed to run concurrent with his federal sentence in exchange for his guilty plea in the federal case. Dkt. 1-2, at 2–4. He claims to have only pleaded guilty to the federal charges pursuant to the concurrent sentence allegedly promised in the supposed global resolution. Dkt. 1, at 4.

Within one month of being released from federal incarceration, the Oregon state prosecutor charged Waters with crimes arising out of the same incident. Dkt. 1-3, at 4. Waters is willing to plead guilty to the state charges only if the Oregon state prosecutor recommends to the Oregon court that his federal sentence and state sentence run concurrently, citing the purported global resolution. Dkt. 1-2, at 5–6. The Oregon state

prosecutor refuses to make such a recommendation. Id. Waters claims the refusal constitutes a breach of their plea agreement. Id. at 2. Waters raised this issue to the Oregon court, but it found no such agreement had been reached between Waters and the Oregon state prosecutor. Dkt. 12-2. According to Court records, his Oregon state jury trial is currently scheduled to begin on July 27 of this year. OREGON JUDICIAL DEPARTMENT,

https://webportal.courts.oregon.gov/portal/Home/WorkspaceMode?p=0 (last visited June 30, 2026). Waters then moved this Court for collateral relief under 28 U.S.C. § 2255. Dkt. 1. He asserts that: (1) the global resolution was breached, and (2) his counsel was deficient for having him “sign a plea deal [he] believed was a global resolution.” Id. at 4. III. LEGAL STANDARD

A. 28 U.S.C. § 2255 Pursuant to 28 U.S.C. § 2255, there are four grounds under which a federal court may grant relief to a prisoner who challenges the imposition or length of his incarceration: (1) “the sentence was imposed in violation of the Constitution or laws of the United States;”

(2) “the court was without jurisdiction to impose such sentence;” (3) “the sentence was in excess of the maximum authorized by law;” or (4) “the sentence is otherwise subject to collateral attack.” 28 U.S.C. § 2255(a). Relief under § 2255 is afforded “[i]f the court finds 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(b). Further, “a district court must grant a hearing to determine the validity of a petition brought under that section ‘[u]nless the motions and the files and records of the case conclusively show that the prisoner is entitled to no relief.’” United States v. Baylock, 20 F.3d 1458, 1465 (9th Cir. 1994) (quoting § 2255). “In determining whether a hearing and findings of fact and conclusions of law are required,

‘[t]he standard essentially is whether the movant has made specific factual allegations that, if true, state a claim on which relief could be granted.’” United States v. Withers, 638 F.3d 1055, 1062 (9th Cir. 2011) (quoting United States v. Schaflander, 743 F.2d 714, 717 (9th Cir. 1984)). “[A] district court may summarily dismiss a § 2255 motion only if the allegations in the motion, when viewed against the record, do not give rise to a claim for relief or are ‘palpably incredible or patently frivolous.’” Id. at 1062–63 (quoting Schaflander, 743 F.2d at 717). In a § 2255 motion, conclusory statements are insufficient to require a hearing.

United States v. Hearst, 638 F.2d 1190, 1194 (9th Cir. 1980); see also James v.

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Joel Aaron Waters v. United States of America, Counsel Stack Legal Research, https://law.counselstack.com/opinion/joel-aaron-waters-v-united-states-of-america-idd-2026.