Lindsey v. United States

CourtDistrict Court, N.D. Indiana
DecidedJune 24, 2025
Docket3:24-cv-00555
StatusUnknown

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

Bluebook
Lindsey v. United States, (N.D. Ind. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA SOUTH BEND DIVISION

LACI LINDSEY,

Petitioner, v. CAUSE NO. 3:24cv555 DRL 3:22cr52 DRL

UNITED STATES OF AMERICA

Respondent.

OPINION AND ORDER Laci Lindsey, a prisoner without a lawyer, filed a pro se petition to vacate or correct her sentence under 28 U.S.C. § 2255 and to appoint counsel. After reviewing the record and conducting an evidentiary hearing on one issue, the court grants the § 2255 in one part, affords her additional time to perfect a timely direct appeal, and otherwise denies the petition. BACKGROUND Ms. Lindsey sold nearly 750 grams of methamphetamine to a confidential source. She sold a total of 295 grams from her house over five occasions. Lab testing from one sale confirmed it to be 100 percent pure. She also facilitated a purchase of one pound (441 grams) of methamphetamine, coordinating contact between the confidential source and her supplier, then driving the supplier to the buy. Testing determined it was 99 percent pure. Law enforcement’s search of her house located methamphetamine, a ledger, scale, baggies, and other paraphernalia. On July 13, 2022, she was indicted for distributing 50 grams or more of methamphetamine. See 21 U.S.C. §§ 841(a)(1), (b)(1)(A). On March 22, 2023, she pleaded guilty to the charged offense with a plea agreement. For sentencing, she asserted four objections to the presentence report, including to the drug quantity calculation and to the drug premises enhancement. Trial counsel failed to file a sentencing memorandum by the deadline, and the court (then presided by Judge Robert L. Miller, Jr.) denied an extension. At the July 10 sentencing, the court gave Ms. Lindsey and trial counsel additional time to review the presentence report together because she had not yet received it [112 Tr. 2-4]. The

court overruled her objections to the drug quantity calculation and drug premises enhancement and sentenced her to 80 months imprisonment, a downward variance from her guideline range of 108-135 months. She did not appeal. In February the next year, Ms. Lindsey asked for a sentence reduction under Amendment 821; the court appointed her a federal public defender and ultimately denied the motion because her sentence was lower than the low end of the new guideline range that incorporated the offense level decrease for zero-point offenders.

Ms. Lindsey filed this § 2255 petition on July 8, 2024. The government responded on August 22, 2024, and she filed her reply on October 4, 2024. She moved a second time for compassionate release (a sentence reduction) on March 10, 2025 (addressed by separate order). On April 10, 2025, the court determined an evidentiary hearing was needed to evaluate a portion of Ms. Lindsey’s § 2255 petition—that her trial counsel failed to file an appeal after being asked to do so. See Garza v. Idaho, 586 U.S. 232 (2019); Roe v. Flores-Ortega, 528 U.S. 470 (2000);

Torres-Chavez v. United States, 828 F.3d 582, 586 (7th Cir. 2016); see also 28 U.S.C. § 2255(b). The court appointed counsel to represent her at the hearing for this limited purpose.1 See 18 U.S.C.

1 The court thus granted her motion for counsel in this lone respect. Outside of an evidentiary hearing, there is generally no right to counsel in § 2255 proceedings. Rauter v. United States, 871 F.2d 693, 695 (7th Cir. 1989). In determining whether a court should exercise its discretion to appoint counsel, courts consider whether, “given the difficulty of the case and the litigant’s ability, she could not obtain justice without an attorney, she could not obtain a lawyer on her own, and she would have had a reasonable chance of winning with a lawyer at her side.” Forbes v. Edgar, 112 F.3d 262, 264 (7th Cir. 1997); see Moreland v. Eplett, 18 F.4th 261, 272 (7th Cir. 2021). The other issues, for reasons articulated in this opinion, she ably presented otherwise. § 3006A; Rule 8(c) of Rules 2 Governing Section 2255 Proceedings. On June 13, the court held an evidentiary hearing on her Garza claim. STANDARD In extraordinary situations, the court may vacate, set aside, or correct a prisoner’s sentence. 28 U.S.C. § 2255(a); Hays v. United States, 397 F.3d 564, 566-67 (7th Cir. 2005). The writ

of habeas corpus is secured by the United States Constitution: “The Privilege of the Writ of Habeas Corpus shall not be suspended, unless when in Cases of Rebellion or Invasion the public Safety may require it.” U.S. Const., Art. I, § 9, cl. 2. Historically, criminal defendants subject to a final conviction were entitled to such relief only if the court that rendered the judgment lacked jurisdiction. Ex parte Watkins, 28 U.S. 193, 202-03 (1830). The writ has since been expanded to provide prisoners relief from various violations of the Constitution, laws, or treaties of the United

States. 28 U.S.C. § 2255(a); Danforth v. Minnesota, 552 U.S. 264, 272 (2008); Estelle v. McGuire, 502 U.S. 62, 68 (1991). This writ is not a substitute for direct appeal. Doe v. United States, 51 F.3d 693, 698 (7th Cir. 1995). When reviewing a § 2255 petition, the court examines the petition and the entire record. The court will hold an evidentiary hearing when the petitioner alleges facts that, if proven, would entitle her to relief. Torres-Chavez, 828 F.3d at 586; see also 28 U.S.C. § 2255(b). Allegations that

prove merely “vague, conclusory, or palpably incredible” rather than detailed and specific won’t suffice. Machibroda v. United States, 368 U.S. 487, 495 (1962). Likewise, when the petition and records conclusively show the petitioner isn’t entitled to relief, the court needn’t hold an evidentiary hearing. Boulb v. United States, 818 F.3d 334, 339 (7th Cir. 2016). DISCUSSION Ms. Lindsey challenges her sentence on grounds of ineffective assistance of counsel. Although she waived much of her right to appeal or contest her conviction in her plea agreement, she retained a right to contest her conviction or sentence on this basis. The Sixth Amendment to the United States Constitution guarantees a defendant the right

to counsel—including the right to effective assistance of counsel. McMann v. Richardson, 397 U.S. 759, 771 n.14 (1970). To show a violation of this right, a petitioner must establish that (1) her counsel’s performance was deficient, and (2) the deficient performance was prejudicial. Strickland v. Washington, 466 U.S. 668, 687 (1984). “A defendant’s failure to satisfy either prong is fatal to [her] claim.” Ebbole v.

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Lindsey v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lindsey-v-united-states-innd-2025.