Laseter v. United States of America (INMATE 3)

CourtDistrict Court, M.D. Alabama
DecidedAugust 17, 2021
Docket2:18-cv-00444
StatusUnknown

This text of Laseter v. United States of America (INMATE 3) (Laseter v. United States of America (INMATE 3)) is published on Counsel Stack Legal Research, covering District Court, M.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Laseter v. United States of America (INMATE 3), (M.D. Ala. 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA NORTHERN DIVISION

TAURUS RASHONE LASETER, ) ) Petitioner, ) ) v. ) CASE NO. 2:18-CV-444-MHH-KFP ) UNITED STATES OF AMERICA, ) ) Respondent. )

RECOMMENDATION OF THE MAGISTRATE JUDGE Taurus Rashone Laseter is before the Court with his Motion to Vacate, Set Aside, or Correct Sentence Under 28 U.S.C. § 2255. CIV. Doc. 1.1 For the reasons discussed below, the Court finds Laseter’s § 2255 Motion should be DENIED without an evidentiary hearing and DISMISSED with prejudice. I. BACKGROUND On November 4, 2015, Laseter pled guilty under a plea agreement to conspiracy to possess with intent to distribute controlled substances (5 kilograms or more of cocaine and a detectable amount of marijuana) in violation of 21 U.S.C. §§ 846, 841(a)(1) (Count One) and possessing a firearm to further a drug trafficking crime in violation of 18 U.S.C. § 924(c)(1)(A)(i) (Count Three).2 CRIM. Doc. 127. After a sentencing hearing on April

1 References to document numbers in this action are designated as “CIV. Doc.,” and references to document numbers assigned by the Clerk of Court in the underlying criminal case (Case No. 2:15-CR-195-MHH) are designated as “CRIM. Doc.” Pinpoint citations are to the page of the electronically filed document in the Court’s CM/ECF filing system, which may not correspond to pagination on the “hard copy” of the document presented for filing. 2 Count Two of the indictment, which charged Laseter with unlawful use of a communication facility (21 U.S.C. § 843(b)), was dismissed as part of the plea agreement. CRIM. Doc. 71 at 4. 12, 2017, the district court sentenced Laseter to 300 months in prison—240 months on the drug conspiracy count (Count One) and a consecutive term of 60 months on the gun count (Count Three). CRIM. Doc. 126. Laseter did not appeal.3

On April 26, 2018, Laseter filed his § 2255 Motion asserting these claims: 1. Counsel was ineffective for failing to communicate with him and inform him of the relevant circumstances and likely consequences of pleading guilty.

2. Counsel was ineffective for failing to conduct an “adequate and independent” pretrial investigation.

3. Counsel was ineffective for failing to negotiate a more favorable plea agreement.

4. Counsel was ineffective for failing to discuss and explain the presentence investigation report.

5. Counsel was ineffective for failing to file substantive objections to the presentence investigation report.

6. Counsel was ineffective for failing to argue for mitigation of his punishment and object to his sentence as substantively unreasonable.

CIV. Doc. 1 at 4–5. II. STANDARD OF REVIEW A. General Standard of Review Because collateral review is not a substitute for direct appeal, the grounds for collateral attack on final judgments under 28 U.S.C. § 2255 are limited. A prisoner may have relief under § 2255 if the court imposed a sentence that (1) violated the Constitution

3 The plea agreement contained a provision in which Laseter waived his rights to appeal and file a § 2255 motion except to raise claims of ineffective assistance of counsel or prosecutorial misconduct. CRIM. Doc. 71 at 6–7. or laws of the United States, (2) exceeded its jurisdiction, (3) exceeded the maximum authorized by law, or (4) is otherwise subject to collateral attack. See 28 U.S.C. § 2255;

United States v. Phillips, 225 F.3d 1198, 1199 (11th Cir. 2000). “Relief under 28 U.S.C. § 2255 ‘is reserved for transgressions of constitutional rights and for that narrow compass of other injury that could not have been raised in direct appeal and would, if condoned, result in a complete miscarriage of justice.’” Lynn v. United States, 365 F.3d 1225, 1232 (11th Cir. 2004) (citations omitted).

B. Standard for Claims of Ineffective Assistance of Counsel A claim of ineffective assistance of counsel is evaluated against the two-part test announced in Strickland v. Washington, 466 U.S. 668 (1984). First, a petitioner must show that “counsel’s representation fell below an objective standard of reasonableness.” Id. at 689. Second, the petitioner must show that “there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different.”

Id. at 694. See Chandler v. United States, 218 F.3d 1305, 1313 (11th Cir. 2000). Scrutiny of counsel’s performance is “highly deferential,” and the Court indulges a “strong presumption” that counsel’s performance was reasonable. Chandler, 218 F.3d at 1314 (internal quotation marks omitted). The Court will “avoid second-guessing counsel’s performance: It does not follow that any counsel who takes an approach [the Court] would

not have chosen is guilty of rendering ineffective assistance.” Id. (internal quotation marks and brackets omitted). “Given the strong presumption in favor of competence, the petitioner’s burden of persuasion—though the presumption is not insurmountable—is a heavy one.” Id. As for the second prong of the Strickland test, a “reasonable probability is a probability sufficient to undermine confidence in the outcome.” Id. The prejudice prong

does not focus only on the outcome; rather, to establish prejudice, the petitioner must show that counsel’s deficient representation rendered the result of the trial fundamentally unfair or unreliable. See Lockhart v. Fretwell, 506 U.S. 364, 369 (1993) (“[A]n analysis focusing solely on mere outcome determination, without attention to whether the result of the proceeding was fundamentally unfair or unreliable, is defective.”). “Unreliability or unfairness does not result if the ineffectiveness of counsel does not deprive the defendant

of any substantive or procedural right to which the law entitles him.” Id. at 372. The Strickland standard for evaluating claims of ineffective assistance of counsel is applicable to guilty pleas. Hill v. Lockhart, 474 U.S. 52, 58 (1985). A petitioner alleging ineffective assistance in this context must establish that counsel’s performance was deficient (i.e., professionally unreasonable) and that counsel’s deficient performance

“affected the outcome of the plea process.” Id. at 59. Thus, to establish prejudice, a petitioner “must show that there is a reasonable probability that, but for counsel’s errors, he would . . . have pleaded [not] guilty and would . . . have insisted on going to trial.” Id. A mere allegation by a defendant that he would have insisted on going to trial but for counsel’s errors is insufficient to establish prejudice; rather, the Court will look to the

factual circumstances surrounding the plea to determine whether the defendant would have proceeded to trial. See Miller v.

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Bluebook (online)
Laseter v. United States of America (INMATE 3), Counsel Stack Legal Research, https://law.counselstack.com/opinion/laseter-v-united-states-of-america-inmate-3-almd-2021.