Lane v USA

2015 DNH 042
CourtDistrict Court, D. New Hampshire
DecidedMarch 6, 2015
Docket14-cv-536-PB
StatusPublished

This text of 2015 DNH 042 (Lane v USA) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lane v USA, 2015 DNH 042 (D.N.H. 2015).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Ryan Patrick Lane

v. Civil No. 14-cv-536-PB Opinion No. 2015 DNH 042 United States of America

MEMORANDUM AND ORDER

Ryan Patrick Lane pleaded guilty in this Court to three

bank robberies, two of which took place in Massachusetts and one

of which took place in New Hampshire. He was sentenced to 168

months in prison. He now moves pursuant to 28 U.S.C. § 2255 to

withdraw his guilty plea and vacate his sentence. He also moves

to appoint counsel and to convene a hearing on a prior motion

for a non-guideline sentence. For the reasons that follow, I

deny Lane’s motions.

I. BACKGROUND

In August 2013, a grand jury indicted Lane for an April

2013 robbery of a New Hampshire bank. Cr. Doc. No. 1.1 A

1 “Cr. Doc. No.” citations refer to document numbers in the docket of the underlying criminal proceeding (No. 13-cr-084-PB). “Doc. No.” citations refer to document numbers in this proceeding. separate information also charged Lane with two other 2013 bank

robberies that took place in Massachusetts. Cr. Doc. No. 14.

On November 25, 2013, Lane pleaded guilty to the New Hampshire

bank robbery. After waiving venue and indictment, he also

pleaded guilty to the two Massachusetts bank robberies during

the same proceeding. See Cr. Doc. Nos. 16, 17. In March 2014,

I sentenced Lane to one 168-month prison term for each of the

three robberies, with all terms to run concurrently. Cr. Doc.

No. 24 at 2.

II. STANDARD OF REVIEW

Where, as here, no evidentiary hearing is held on a § 2255

motion, I must “take as true the sworn allegations of fact set

forth in the petition unless those allegations are merely

conclusory, contradicted by the record, or inherently

incredible.” Owens v. United States, 483 F.3d 48, 57 (1st Cir.

2007) (internal quotation omitted). In reviewing this pro se

motion, I must construe the petitioner’s pleading liberally.

Ayala Serrano v. Lebron Gonzales, 909 F.2d 8, 15 (1st Cir.

1990).

2 III. ANALYSIS

In his motion, Lane first argues that he received

ineffective assistance from his attorney before he pleaded

guilty. See Doc. No. 1 at 3-6. He then argues that he should

be allowed to withdraw his guilty plea because it was not

knowing and voluntary. See id. at 7-9. I address, and reject,

each argument in turn. I then turn to Lane’s requests for an

evidentiary hearing, the appointment of counsel, and a hearing

regarding his previous motion for a non-guideline sentence. See

id. at 10; Doc. Nos. 5, 8.

A. Ineffective Assistance of Counsel

Lane argues that he received ineffective assistance

from his attorney before he pleaded guilty. To succeed on a

claim of ineffective assistance of counsel, a § 2255 petitioner

must show both “deficient performance by counsel and resulting

prejudice.” Peralta v. United States, 597 F.3d 74, 79 (1st Cir.

2010) (citing Strickland v. Washington, 466 U.S. 668, 687

(1984)); see also Kimmelman v. Morrison, 477 U.S. 365, 382

(1986) (adopting the two-prong Strickland standard for claims of

ineffective assistance of counsel on habeas review). Although a

3 petitioner must satisfy both the deficient performance and

prejudice prongs to prevail on a claim of ineffective

assistance, “a reviewing court need not address both

requirements if the evidence as to either is lacking.” Sleeper

v. Spencer, 510 F.3d 32, 39 (1st Cir. 2007). To satisfy the

“deficient performance” prong of this standard, a petitioner

must prove that his trial counsel’s representation fell below

“an objective standard of reasonableness.” Pina v. Maloney, 565

F.3d 48, 54 (1st Cir. 2009); Owens v. United States, 483 F.3d

48, 57 (1st Cir. 2007). To establish prejudice, a petitioner

must demonstrate “that, but for counsel’s unprofessional error,

there is a reasonable probability that the result of the

proceeding would have been different. A reasonable probability

is a probability sufficient to undermine confidence in the

outcome.” Sleeper, 510 F.3d at 39 (internal citation omitted).

Lane raises four separate claims of ineffective assistance

by his attorney. See Doc. No. 1. None of Lane’s four claims,

however, meet the ineffective assistance standard.

1. Competency Hearing

Pointing to his history of mental illness, Lane first

argues that his attorney was ineffective for failing to move for

4 a competency hearing after he was arrested. See Doc. No. 1 at

3.2 This claim fails because Lane has not shown that his

attorney’s advice to plead guilty without moving for a

competency hearing was objectively unreasonable.

There is no doubt that Lane has suffered from mental

illness for much of his life. In the past, he has been

diagnosed at various points with attention deficit hyperactivity

disorder, unspecified psychotic disorder, bipolar disorder,

posttraumatic stress disorder, provisional cognitive disorder

secondary to traumatic brain injury, and provisional personality

change also secondary to traumatic brain injury. Cr. Doc. No.

19 at 26-27. He has tried to commit suicide on multiple

occasions. Id. at 26. He also struggles with alcohol and drug

dependency. See id. at 27.

The record, however, shows that Lane’s attorney knew of his

client’s history of mental illness during his representation.

As Lane himself notes, his attorney filed notice of an insanity

2 Lane cites Federal Rule of Criminal Procedure 12.2 as the basis on which a defendant may move for a competency hearing. See Doc. No. 1 at 3. In fact, a defendant may move for a competency hearing under 18 U.S.C. § 4241, not Rule 12.2, which allows either the court or the government to compel a defendant to undergo a competency hearing under certain circumstances. See 18 U.S.C. § 4241(a); Fed. R. Crim. P. 12.2(c). 5 defense under Federal Rule of Criminal Procedure 12.2(a) almost

one month before Lane pleaded guilty. See Cr. Doc. No. 12.

Lane’s attorney spoke about Lane’s mental illness during the

guilty plea hearing. See Cr. Doc. No. 28 at 16-17. Lane even

acknowledges in his petition that he and his attorney had

“considerable discussion about the particulars of the crime and

the defendants [sic] state of mind at the time the alleged crime

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Related

Peralta v. United States
597 F.3d 74 (First Circuit, 2010)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Kimmelman v. Morrison
477 U.S. 365 (Supreme Court, 1986)
Colorado v. Connelly
479 U.S. 157 (Supreme Court, 1986)
United States v. McGill
11 F.3d 223 (First Circuit, 1993)
United States v. Lebron
76 F.3d 29 (First Circuit, 1996)
David v. United States
134 F.3d 470 (First Circuit, 1998)
Ellis v. United States
313 F.3d 636 (First Circuit, 2002)
Owens v. United States
483 F.3d 48 (First Circuit, 2007)
Sleeper v. Spencer
510 F.3d 32 (First Circuit, 2007)
Pina v. Maloney
565 F.3d 48 (First Circuit, 2009)
Chris Calabrese v. United States
507 F.2d 259 (First Circuit, 1974)
United States v. Mohammed Y. Butt
731 F.2d 75 (First Circuit, 1984)
United States v. Robert Gerald Knott
894 F.2d 1119 (Ninth Circuit, 1990)
Nestor Ayala Serrano v. Cruz Lebron Gonzalez
909 F.2d 8 (First Circuit, 1990)
Jose Rosado Acha v. United States
910 F.2d 28 (First Circuit, 1990)
United States v. Felix Garcia
94 F.3d 57 (Second Circuit, 1996)
United States v. Charles Palmer
203 F.3d 55 (First Circuit, 2000)

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