Kelbch v. United States

CourtDistrict Court, D. Nevada
DecidedJanuary 7, 2021
Docket3:20-cv-00361
StatusUnknown

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

Bluebook
Kelbch v. United States, (D. Nev. 2021).

Opinion

1 2 3 4 5 6 UNITED STATES DISTRICT COURT

7 DISTRICT OF NEVADA

8 * * * 9 UNITED STATES OF AMERICA, Case No. 3:17-cr-00040-LRH-WGC

10 Respondent/Plaintiff, ORDER v. 11 DEVIN RAY KELBCH, 12 Petitioner/Defendant.

13 14 Before the Court is petitioner Devin Ray Kelbch’s (“Kelbch”) motion, to vacate, set aside, 15 or correct his sentence pursuant to 28 U.S.C. § 2255 (ECF No. 36). Kelbch filed his motion 16 considering the recent ruling in Rehaif v. United States, 139 S. Ct. 2191 (2019). The Government 17 opposed (ECF No. 38), arguing that Kelbch’s claims are procedurally barred because he did not 18 raise them on direct appeal. In his reply (ECF No. 39), Kelbch maintains that the constitutional 19 errors are structural. For the reasons contained within this Order, the Court denies his motion and 20 denies him a certificate of appealability. 21 I. BACKGROUND 22 On March 26, 2017, Reno police officers responded to a report of an individual passed out 23 in a vehicle in an apartment parking lot. ECF No. 38, at 2. Upon arrival, the officers found Kelbch 24 asleep at the wheel of a vehicle with the keys in the ignition while the vehicle was running. After 25 waking up, Kelbch gave the officers a false identity because he was on parole and did not want to 26 get revoked. Once officers discovered Kelbch’s true identity, they also determined that the vehicle 27 was stolen. In the vehicle, the officers found tools commonly used in burglaries, and, most notably, 1 Kelbch is an ex-felon, and in February 2018, Klebch pled guilty to Unlawful Possession of 2 a Firearm by a Previously Convicted Felon. ECF No. 33. This Court sentenced Kelbch to 63 3 months’ imprisonment followed by three years of supervised release. Kelbch did not appeal. 4 Now, Kelbch seeks to vacate his sentence pursuant to 28 U.S.C. § 2255. 5 II. LEGAL STANDARD 6 Pursuant to 28 U.S.C. § 2255, a petitioner may file a motion requesting the court which 7 imposed sentence to vacate, set aside, or correct the sentence. 28 U.S.C. § 2255(a). Such a motion 8 may be brought on the following grounds: (1) “the sentence was imposed in violation of the 9 Constitution or laws of the United States;” (2) “the court was without jurisdiction to impose such 10 sentence;” (3) “the sentence was in excess of the maximum authorized by law;” or (4) the sentence 11 “is otherwise subject to collateral attack." Id.; see United States v. Berry, 624 F.3d 1031, 1038 (9th 12 Cir. 2010). When a petitioner seeks relief pursuant to a right newly recognized by a decision of 13 the United States Supreme Court, a one-year statute of limitations applies. 28 U.S.C. § 14 2255(f). That one-year limitation period begins to run from "the date on which the right asserted 15 was initially recognized by the Supreme Court." Id. § 2255(f)(3). Kelbch filed his petition on June 16 16, 2020. 17 On June 21, 2019, the Supreme Court decided Rehaif, overturning established Ninth Circuit 18 precedent. 139 S. Ct. 2191. In the past, the government was only required to prove that a defendant 19 knowingly possessed a firearm under 18 U.S.C. §§ 922(g) and 924(a)(2). Id. at 2200. Now, under 20 Rehaif, the government “must prove both that the defendant knew he possessed a firearm and that 21 he knew that he belonged to the relevant category of persons barred from possessing a firearm.” 22 Id. 23 III. DISCUSSION 24 Kelbch argues that by leaving out the new Rehaif element from the original indictment, 25 this Court lacked jurisdiction. ECF No. 36, at 14. Kelbch further alleges the omission in the 26 indictment violated both his Fifth Amendment guarantee that a grand jury find probable cause to 27 support all the necessary elements of a crime, and his Sixth Amendment right to effective 1 A. Unconditional Guilty Plea 2 The government contends that by pleading guilty unconditionally, Kelbch waived his right 3 to make any non-jurisdictional challenges to the indictment; specifically, his Fifth and Sixth 4 Amendment challenges. See Tollet v. Henderson, 411U.S. 258, 267 (1973). ECF No. 38, at 14. 5 As part of his plea, Kelbch waived “all collateral challenges, including any claims under 6 28 U.S.C. § 2255, to his conviction, sentence, and the procedure by which the Court adjudicated 7 guilt and imposed sentence, except non-waivable claims of ineffective assistance of counsel.” ECF 8 No. 25, at 12. Consequently, Kelbch waived “all non-jurisdictional defenses and cures all 9 antecedent constitutional defects, allowing only an attack on the voluntary and intelligent character 10 of the plea.” United States v. Brizan, 709 F.3d 864, 866–67 (9th Cir. 2013). Considering the plea’s 11 cut-and-dry language, the Court finds Kelbch’s claims are barred by his guilty plea even in view 12 of the exceptions to Tollett v. Henderson, 411 U.S. 258 (1973).1 Nevertheless, the Court still finds 13 it necessary to address the jurisdictional and procedural default arguments below. 14 B. Jurisdiction 15 This Court “has jurisdiction of all crimes cognizable under the authority of the United 16 States….” Lamar v. United States, 240 U.S. 60, 65 (1916). Any “objection that the indictment does 17 not charge a crime against the United States goes only to the merits of the case,” and does not 18 deprive the court of jurisdiction. Id.; see also United States v. Cotton, 535 U.S. 625, 630 (2020) 19 (reiterating Lamar). Quite importantly, the Ninth Circuit and decisions within the District of 20 Nevada have relied on the principle announced in Cotton in cases considering the aftermath of 21 Rehaif. See, e.g., United States v. Espinoza, 816 F. App'x 82, 84 (9th Cir. 2020) (“[T]he 22 indictment's omission of the knowledge of status requirement did not deprive the district court of 23 jurisdiction.”); see also United States v. Miller, Case No. 3:15-cr-00047-HDM-WGC (D. Nev. 24 25 1 Tollett limited federal habeas challenges to pre-plea constitutional violations. 411 U.S. at 267. Exceptions to this 26 general rule include a claim which the state cannot “constitutionally prosecute.” Class v. U.S., 138 S. Ct. 789, 805 (2018) (quoting Menna v. New York, 423 U.S. 61, 63 (1975) (per curiam)). While Kelbch argues such an exception 27 exists in the present instance (ECF No. 36, at 21), the Court agrees with other well-reasoned decisions in the District of Nevada which hold it does not. See United States v. Abundis, Case No. 2:18-cr-00158-MMD-VCF-1 (D. Nev. Nov. 1 Dec. 8, 2020); United States v. Baustamante, Case No. 2:16-cr-00268-APG (D. Nev. Dec. 7, 2 2020). 3 Therefore, pursuant to Ninth Circuit precedent and decisions in this District, the Court had 4 and continues to have jurisdiction over Kelbch’s case despite Rehaif. 5 C.

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Related

Tollett v. Henderson
411 U.S. 258 (Supreme Court, 1973)
Menna v. New York
423 U.S. 61 (Supreme Court, 1975)
Reed v. Ross
468 U.S. 1 (Supreme Court, 1984)
Arizona v. Fulminante
499 U.S. 279 (Supreme Court, 1991)
Bousley v. United States
523 U.S. 614 (Supreme Court, 1998)
Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
United States v. Cotton
535 U.S. 625 (Supreme Court, 2002)
Abbott v. Abbott
560 U.S. 1 (Supreme Court, 2010)
United States v. Berry
624 F.3d 1031 (Ninth Circuit, 2010)
United States v. Francheska Brizan
709 F.3d 864 (Ninth Circuit, 2013)
Wesley Kingsbury v. United States
900 F.3d 1147 (Ninth Circuit, 2018)
Rehaif v. United States
588 U.S. 225 (Supreme Court, 2019)
United States v. Lopez-Soto
960 F.3d 1 (First Circuit, 2020)
United States v. Rodney Lavalais
960 F.3d 180 (Fifth Circuit, 2020)
United States v. Jevonne Coleman
961 F.3d 1024 (Eighth Circuit, 2020)
United States v. Kordell Payne
964 F.3d 652 (Seventh Circuit, 2020)
United States v. Tuan Luong
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Lamar v. United States
240 U.S. 60 (Supreme Court, 1916)

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Kelbch v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kelbch-v-united-states-nvd-2021.