Jones v. United States

CourtDistrict Court, E.D. Missouri
DecidedSeptember 27, 2022
Docket1:19-cv-00089
StatusUnknown

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

Bluebook
Jones v. United States, (E.D. Mo. 2022).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI SOUTHEASTERN DIVISION

CARLOS SANCHAZE JONES, ) ) Petitioner ) ) vs. ) Case No. 1:19-cv-00089-AGF ) UNITED STATES OF AMERICA, ) ) Respondent. ) MEMORANDUM AND ORDER This matter is before the Court on Petitioner Carlos Sanchaze Jones’s motion filed under 28 U.S.C. § 2255 to vacate, set aside, or correct his sentence. On July 20, 2018, Petitioner pled guilty to one count of distributing 50 grams or more of a mixture or substance containing methamphetamine, in violation of 21 U.S.C. §§ 841(a)(1) and 841(b)(1)(B)(viii). The Court accepted Petitioner’s plea, and on December 14, 2018, sentenced Petitioner to 120 months’ imprisonment. In his pro se motion under § 2255, Petitioner appears to claim that the Court has not established that it had subject-matter jurisdiction, and asserts that defense counsel’s ineffective assistance contributed to this somehow. He also asserts that his counsel was ineffective for failing to challenge at sentencing Petitioner’s status as a career offender under the United States Sentencing Guidelines (the “Guidelines”) §4B1.1 and failing to challenge whether the drug quantity at issue was sufficient under the relevant statute. As the record conclusively demonstrates that Petitioner is not entitled to relief, the Court will deny Petitioner’s motion without a hearing. BACKGROUND Criminal Proceedings

Petitioner was indicted on April 19, 2018, and charged with one count of distributing 50 grams or more of a mixture or substance containing methamphetamine, in violation of 21 U.S.C. §§ 841(a)(1) and 841(b)(1)(B)(viii). As noted above, Petitioner pled guilty as charged on July 20, 2018, pursuant to a written plea agreement. United States v. Jones, Case No. 1:18CR056 AGF, Doc. No. 29.1 As part of the guilty plea agreement signed by both parties, Petitioner stipulated to

the following facts. On October 10, 2017, an undercover officer with the Southeast Missouri Drug Task Force met with Petitioner at an address in Cape Girardeau, Missouri. Petitioner provided the officer with seven grams of methamphetamine in exchange for $260. On October 17, 2017, Petitioner left an amount of methamphetamine for the officer in a shed owned by Petitioner’s associate. The officer provided the associate with

$1,400 as payment, which was to be given to Petitioner at a later date. The Missouri State Highway Patrol Crime Laboratory analyzed the drugs and determined it to be 51.27 grams of a mixture or substance containing methamphetamine. On October 25, 2017, Petitioner again provided the undercover officer with approximately two ounces of methamphetamine in exchange for $1,400. The Missouri

1 References to the underlying criminal case are designated as “Crim. Doc. No. ___”). 2 State Highway Patrol Crime Laboratory analyzed the drugs and determined it to be 56.13 grams of a mixture or substance containing methamphetamine. Id.

At the change-of-plea hearing held on the day the plea agreement was executed, Petitioner represented that he was satisfied with his attorney’s performance, that his attorney did everything Petitioner asked him to do, and that there was nothing that Petitioner could think of that his attorney should have done but did not do. Petitioner confirmed that he understood the terms of the indictment and plea agreement; that he understood the rights he was giving up by pleading guilty, including all of his rights

associated with his right to a trial; and that he was guilty of the crime to which he was pleading guilty. The Court ascertained the factual basis for the guilty plea and accepted the plea as knowing, intelligent, and voluntary. Crim. Doc. No. 50. Although the parties had estimated in their plea agreement that the base offense level under the Guidelines was 24, based upon the relevant conduct, they agreed that

either party could request a sentence above or below the Guidelines range ultimately determined by the Court. The plea agreement further provided that the Court was not bound by the parties’ Guidelines recommendations; recognized that the parties may not have foreseen all applicable Guidelines; and advised Petitioner that the Court may, in its discretion, apply or not apply any Guidelines provision despite the parties’ agreement.

Crim. Doc. No. 29. At the plea hearing, Petitioner was likewise advised that the Court would ultimately determine Petitioner’s sentence, without being bound by the parties’

3 recommendations. Crim. Doc. No. 50, at 21-22, 24-25. Petitioner was also expressly advised that he could receive the maximum term of imprisonment, the maximum fine, or

both. Id. at 25, 27. After Petitioner pled guilty but before sentencing, the United States Probation Office issued its preliminary presentence investigation report (“PSR”). In the preliminary PSR, the Probation Office stated that Petitioner should be classified as a career offender under the Guidelines due to his prior felony convictions for attempted robbery in the first degree and distribution of a controlled substance. Based on this conclusion, the PSR then

determined an advisory Guidelines range of 188-235 months’ imprisonment. Crim. Doc. No. 31. Petitioner’s attorney objected in writing to the career offender classification, asserting that Petitioner’s prior attempted robbery conviction was not a crime of violence as required for career offender status. The Probation Office did not agree with the objection, and concluded in the final PSR that Petitioner qualified as a career offender.

Crim. Doc. No. 36, at 29-30. On December 14, 2018, the Court held the sentencing hearing at which Petitioner appeared through counsel. Petitioner confirmed at the hearing that he had reviewed the PSR with counsel. The Court heard argument on Petitioner’s objection to the career offender classification. Following argument, the Court concluded that the objection was

not well taken. However, the Court granted a downward variance from the Guidelines sentencing range in order to impose a 120-month sentence.

4 The Court stated that it believed a sentence of 120 months’ imprisonment would have been appropriate irrespective of its ruling on Petitioner’s objection to the career

offender classification because, in the event that Petitioner not been deemed to be a career offender, the Court would have varied upward from the applicable Guidelines range and still arrived at 120 months’ imprisonment. The Court explained that this upward variance would be due to Petitioner’s substantial and extensive criminal history, as well as his poor conduct and criminal offenses committed while on supervision or parole.

Nevertheless, having found that the career offender classification applied, the Court varied downward from the applicable Guidelines range and explained its reasoning for the downward variance, including Petitioner’s upbringing and substance abuse history and the fact that his criminal history was somewhat overstated due to the amount of time that had passed since his attempted robbery conviction. Petitioner did not file an appeal.

Motion to Vacate As noted above, the Court discerns three claims from Petitioner’s pro se motion under § 2255. First, Petitioner contends that counsel was ineffective for failing to argue that the Court lacked subject matter jurisdiction.

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Jones v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jones-v-united-states-moed-2022.