Key v. United States

CourtDistrict Court, S.D. Georgia
DecidedMarch 28, 2025
Docket2:23-cv-00026
StatusUnknown

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

Bluebook
Key v. United States, (S.D. Ga. 2025).

Opinion

65IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF GEORGIA BRUNSWICK DIVISION

TERRY KEY,

Movant, CIVIL ACTION NO.: 2:23-cv-26

v.

UNITED STATES OF AMERICA, (Case No.: 2:21-cr-3)

Respondent.

ORDER and REPORT AND RECOMMENDATION Movant Terry Key (“Key”) filed a 28 U.S.C. § 2255 Motion to Vacate, Set Aside, or Correct his Sentence under 28 U.S.C. § 2255. Doc. 1. Respondent filed a Motion to Dismiss, and Key filed a Response. Docs. 7, 13. For the following reasons, I RECOMMEND the Court GRANT Respondent’s Motion to Dismiss, DENY Key’s § 2255 Motion, DIRECT the Clerk of Court to CLOSE this case and enter the appropriate judgment of dismissal, and DENY Key a Certificate of Appealability and in forma pauperis status on appeal. I DENY Key’s request for an evidentiary hearing. BACKGROUND Key and a co-defendant were indicted for: possession of a controlled substance with intent to distribute, in violation of 21 U.S.C. § 841(a)(1); possession of a firearm in furtherance of a drug trafficking crime, in violation of 18 U.S.C. § 924(c); and possession of a firearm by a prohibited person, in violation of 18 U.S.C. § 922(g)(1). United States v. Key, Case No. 2:21-cr- 3 (“Crim. Case”), ECF No. 1. If convicted, Key faced a 20-year sentence on the controlled substance count and at least 5 years, up to life, on the § 924(c) count, and at least 10 years on the § 922(g) count. Crim. Case, ECF No. 2. Key’s appointed counsel, J. Wrix McIlvaine, filed several pretrial motions on Key’s behalf, including a motion to suppress evidence obtained based on the search warrant, arguing the affidavit supporting the search warrant failed to establish probable cause. Crim. Case, ECF No. 32; id. at ECF Nos. 48–53. I recommended the Court

deny the motion to suppress based on my finding that probable cause existed for the issuance of the warrant and, even if it did not, the good-faith exception barred application of the exclusionary rule. Crim. Case, ECF No. 76. The Honorable Lisa Godbey Wood adopted the Report over Key’s objection. Crim. Case, ECF Nos. 77, 78. The Government then advised the Court that Key wished to enter a plea agreement, whereby he agreed to plead guilty to counts 1 and 2 of the indictment. Crim. Case, ECF Nos. 84, 86. Based on that agreement, Key would be subject to no more than 20 years in prison on the controlled substance count and to a consecutive, mandatory sentence of at least 5 years and up to life in prison on the § 924 count. Crim. Case, ECF No. 86, pp. 2–3. Judge Wood conducted a Rule 11, or change of plea, hearing. Crim. Case, ECF No. 85.

At the outset of the hearing, Judge Wood informed Key the purpose of the hearing was to ensure: (1) Key understood the case pending against him and all of the rights he would waive if Judge Wood accepted his plea; (2) there was a factual basis for the finding of guilt on the charges to which Key was pleading guilty; and (3) pleading guilty was what Key wanted to do. Crim. Case, ECF No. 116, pp. 2–3. Key confirmed that no one was making him, pushing him, or leaning on him to change his plea. Id. at 3. During the plea hearing, Assistant United States Attorney (“AUSA”) Marcela Mateo provided the factual basis for Key’s plea agreement by calling Drug Enforcement Agency Task Force Officer Ryan Alexander (“TFO Alexander”) to testify. Id. at 20–23. Key stated he did not disagree with anything TFO Alexander presented and admitted to the truth of TFO Alexander’s testimony. Id. at 23–24. Judge Wood accepted Key’s guilty plea, adjudged him guilty of counts 1 and 2 of the indictment, and directed the United States Probation Office to prepare a pre-sentence investigation report (“PSR”). Id. at 24. Judge Wood conducted Key’s sentencing hearing on January 12, 2022. Crim. Case,

ECF No. 96. Judge Wood reminded Key he appeared with Mr. McIlvaine for the Rule 11 hearing and she directed the Probation Office to prepare a PSR. Crim. Case, ECF No. 115, p. 2. Judge Wood adopted the probation officer’s factual statements and conclusions about the applicable advisory Sentencing Guidelines, resulting in a total offense level of 15 and criminal history category of VI. Id. at 3. The Guidelines’ range was 41 to 51 months’ imprisonment on count 1 and 60 months’ imprisonment on count 2, to be served consecutively. Id. Mr. McIlvaine offered argument on Key’s behalf. Id. at 4–7. The AUSA presented argument in support of the recommended 108-month sentence. Id. at 8. Judge Wood allowed Key to address the Court. Id. at 8–9. Judge Wood then informed Key she had read the PSR, listened to the attorneys and Key, thought about the 18 U.S.C. § 3553 factors, and considered Key’s extensive criminal history. Id.

at 9. Based on all of these factors, Judge Wood sentenced Key to a 106-month sentence, which was comprised of 46 months on count 1 and a consecutive term of 60 months on count 2. Id. at 10. Key did not file any direct appeal. Key filed the instant § 2255 Motion. Doc. 1. The Government filed a Motion to Dismiss. Doc. 7. Key filed a Response. Doc. 13. This matter is fully briefed and ready for review. DISCUSSION I. The Court Should Deny Key’s Claims of Ineffective Assistance of Counsel A movant bears the burden of showing entitlement to relief under § 2255. Beeman v. United States, 871 F.3d 1215, 1222 (11th Cir. 2017). A movant is not entitled to relief if his

claims “are merely conclusory allegations unsupported by specifics, contentions that are wholly incredible on the face of the record, or so patently frivolous as to warrant summary dismissal.” Adams v. United States, No. 19-11068-C, 2019 WL 4643730, at *1 (11th Cir. Aug. 20, 2019) (citing Tejada v. Dugger, 941 F.2d 1551, 1559 (11th Cir. 1991) (citations omitted)). Criminal defendants have a right to effective assistance of counsel at all critical stages of the proceedings. Strickland v. Washington, 466 U.S. 668 (1984). This right extends to the right to proceed to trial, see Carver v. United States, 722 F. App’x 906 (11th Cir. 2018), during sentencing proceedings, Glover v. United States, 531 U.S. 198, 202 (2001), and on appeal, Philmore v. McNeil, 575 F.3d 1251, 1264 (11th Cir. 2009). To prevail on a claim of ineffective assistance of counsel, the defendant must

demonstrate (1) his counsel’s performance was deficient, i.e., the performance fell below an objective standard of reasonableness, and (2) he suffered prejudice as a result of that deficient performance. Strickland, 466 U.S. at 685–86. The deficient performance requirement concerns “whether counsel’s advice was within the range of competence demanded of attorneys in criminal cases.” Hill v. Lockhart, 474 U.S. 52, 56 (1985). There is a strong presumption counsel’s conduct fell within the range of reasonable professional assistance. Davis v. United States, 404 F. App’x 336, 337 (11th Cir. 2010) (citing Strickland, 466 U.S. at 686).

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Key v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/key-v-united-states-gasd-2025.