Lockhart v. United States

CourtDistrict Court, S.D. West Virginia
DecidedSeptember 16, 2024
Docket3:22-cv-00140
StatusUnknown

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

Bluebook
Lockhart v. United States, (S.D.W. Va. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF WEST VIRGINIA

HUNTINGTON DIVISION

GEORGE MARSHALL LOCKHART, ) ) Movant, ) ) v. ) CIVIL ACTION NO. 3:22-00140 ) (Criminal No. 3:19-00201) UNITED STATES OF AMERICA, ) ) Respondent. )

PROPOSED FINDINGS AND RECOMMENDATION

Pending before the Court is Movant’s Motion Under 28 U.S.C. § 2255 to Vacate, Set Aside or Correct Sentence by a Person in Federal Custody and Supplemental Section 2255 Motion.2 (Civil Action No. 3:22-00140, Document Nos. 160 and 169.) By Standing Order, this matter was referred to the undersigned United States Magistrate Judge for submission of proposed findings of fact and a recommendation for disposition pursuant to 28 U.S.C. § 636(b)(1)(B). (Id., Document No. 162.) FACTUAL AND PROCEDURAL BACKGROUND A. Criminal Action No. 3:19-cr-00201: On January 6, 2020, Movant pled guilty without a plea agreement to one count of Conspiracy to Distribute a Quantity of Heroin and a Mixture or Substance Containing a Detectable Amount of Fentanyl in violation of 21 U.S.C. § 846 (Count One), and one count of Being a Felon in Possession of a Firearm in violation of 18 U.S.C. §§ 922(g)(1) and 924(a)(2) (Count Two).

2 Because Movant is acting pro se, the documents which he has filed in this case are held to a less stringent standard than if they were prepared by a lawyer, and therefore they are construed liberally. See Haines v. Kerner, 404 U.S. 519, 520-21, 92 S.Ct. 594, 30 L.Ed.2d 652 (1972). (Criminal Action No. 3:19-00201, Document Nos. 100, 102, 103.) On June 3, 2020, the District Court sentenced Movant to a total term of 96 months imprisonment, to be followed by a three-year term of supervised release. (Id., Document Nos. 128 and 129.) The District Court further imposed a $200 special assessment. (Id.)

On June 18, 2020, Movant, by counsel, filed his Notice of Appeal. (Id., Document No. 134.) On appeal, Movant challenged the reasonableness of his sentence. (Id., Document No. 149.) By Per Curiam Opinion entered on February 5, 2021, the Fourth Circuit affirmed the judgment of the District Court. (Id., Document Nos. 149 and 150.) B. Section 2255 Motion: On March 18, 2022, Movant, acting pro se, filed his instant Motion Under 28 U.S.C. § 2255 to Vacate, Set Aside, or Correct Sentence by a Person in Federal Custody. (Civil No. 3:22- 00140, Document No. 160.) As grounds for habeas relief, Movant challenges the validity of his conviction under 18 U.S.C. 922(g) based upon Rehaif v. United States, 139 S.Ct. 2191 (2019) and allegations of ineffective assistance of counsel. (Id.) Specifically, Movant states as follows:

This is a Rehaif claim. I did not know I was prohibited. My counsel told me I had to say I knew when I did not nor did I possess a gun. My FPD told me I had to say I possessed a gun and that I knew I was a “prohibited person.” That was not true. I did not understand the “plea agreement.”

(Id.) Additionally, Movant requested permission to amend his Section 2255 Motion to included additional grounds. (Id., Document No. 160, pp. 5 – 7 and Document No. 161.) In support, Movant stated that he had limited access to the law library due to COVID. (Id., Document No. 161.) By Order entered on March 21, 2022, United States District Judge Robert C. Chambers granted Movant’s Motion to Amend and directed that Movant file his Amended Section 2255 Motion by April 18, 2022. (Id., Document No. 164.) Following the granting of two extensions of time, 2 Movant filed his Supplemental Section 2255 Motion on June 30, 2022. (Id., Document Nos. 165 – 169.) In the Supplemental Section 2255 Motion, Movant asserts the following grounds: (1) This is a Rehaif claim of ineffective assistance of counsel. I did not make my plea knowingly and voluntarily.

(2) Ineffective Assistance of Counsel. I did not make my plea knowingly and voluntarily.

(3) The trial court failed to sentence me pursuant to the First Step Act.

(4) The Court erred as the enhancements are incorrect.

(5) The Indictment is faulty.

(6) Ineffective assistance of counsel. This accusation covers Grounds 1 through 5.

(Id., Document No. 169.) By Order entered on July 1, 2022, the undersigned directed court appointed counsel, Federal Public Defender (“FPD”) Wesley P. Page, to file an affidavit responding to Movant’s claims of ineffective assistance of counsel and the United States to file its Answer. (Id., Document No. 170.) On July 26, 2022, FPD Page filed his Affidavit. (Id., Document No. 171.) On September 13, 2022, the United States filed its Response in Opposition to Movant’s Section 2255 Motion and Supplemental Motion. (Id., Document No. 172.) On October 17, 2022, Movant filed his Reply. (Id., Document No. 174.) DISCUSSION The relevant portion of Section 2255 provides as follows: A prisoner in custody under sentence of a court established by Act of Congress claiming the right to be released upon the ground that the sentence was imposed in violation of the Constitution or laws of the United States, or that the court was without jurisdiction to impose such sentence, or that the sentence was in excess of the maximum authorized by law, or is otherwise subject to collateral attack, may move the court which imposed the sentence to vacate, set aside or correct the 3 sentence.

A motion made pursuant to Section 2255 is a collateral attack on a conviction or sentence. To succeed on a Section 2255 motion, the movant must prove that “his sentence or conviction was imposed in violation of the Constitution or law of the United States, that the court was without jurisdiction to impose such a sentence, that the sentence exceeded the maximum authorized by law, or that the sentence otherwise is subject to collateral attack.” 28 U.S.C. § 2255. “A motion collaterally attacking a petitioner’s sentence brought pursuant to § 2255 requires the petitioner to establish his grounds by a preponderance of the evidence.” Sutton v. United States, 2006 WL 36859, * 2 (E.D.Va. Jan. 4, 2006). 1. Ineffective Assistance of Counsel: Indigent criminal defendants have the constitutional right to effective assistance of counsel through direct appeal. Anders v. California, 386 U.S. 738, 87 S.Ct. 1396, 18 L.Ed.2d 493 (1967) When a movant claims ineffective assistance of counsel as a basis for seeking relief under Section 2255, the burden is on the movant to prove that his trial attorney failed to render effective

assistance. Strickland v. Washington, 466 U.S. 668, 689, 104 S.Ct. 2052, 2065, 80 L.Ed.2d 674 (1984). In Strickland, the Court adopted a two-pronged test for determining whether a defendant received adequate assistance of counsel. Id. The first prong is competence. The movant must show that the representation fell below an objective standard of reasonableness. Strickland, 466 U.S. at 687 - 691, 104 S.Ct. at 2064 - 2066.

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Lockhart v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lockhart-v-united-states-wvsd-2024.