Lucas v. United States

CourtDistrict Court, S.D. California
DecidedAugust 19, 2021
Docket3:21-cv-00937
StatusUnknown

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

Bluebook
Lucas v. United States, (S.D. Cal. 2021).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 UNITED STATES OF AMERICA, Case No.: 18cr4224; 21cv937-CAB

12 Plaintiff, ORDER DENYING MOTION TO 13 v. VACATE, SET ASIDE, OR CORRECT SENTENCE UNDER 28 14 TREVON ANTONE LUCAS, U.S.C. § 2255 15 Defendant. 16 17 This matter is before the Court on Petitioner/Defendant Trevon Antone Lucas’s 18 motion to vacate, set aside, or correct sentence under 28 U.S.C. §2255. [Doc. No. 119.] 19 The government has filed an opposition to the motion [Doc. No. 123], and the deadline for 20 Petitioner’s reply has passed. Upon review of the motion and opposition, the Court deems 21 it suitable for submission without oral argument. As explained below, the motion is 22 DENIED. 23 I. Background 24 Trevon Antone Lucas was charged by Indictment with (1) distribution of fentanyl, 25 resulting in the death of C.A.S., in violation of 21 U.S.C. § 841(a)(1) and (b)(1)(C), and 26 (2) conspiracy to distribute hydrocodone, in violation of 21 U.S.C. § 841(a)(1) and 27 28 1 (b)(1)(C) and 846. [Doc. No. 1.] Lucas entered into a plea agreement pursuant to which 2 he agreed to plead guilty to the first charge, and the government agreed to dismiss the 3 remaining charges. [Doc. No. 79.] The plea agreement specified that the crime to which 4 Lucas was pleading guilty carried a maximum penalty of life in prison and a mandatory 5 minimum penalty of 20 years. [Id. at 4.] Defendant also represented that he had had a 6 “full opportunity to discuss all the facts and circumstances of this case with defense counsel 7 and ha[d] a clear understanding of the charges and the consequences of this plea” [Id. at 8 5], and that he was satisfied with his counsel’s representation [Id. at 13]. 9 On April 23, 2019, Lucas pled guilty before Magistrate Judge Barbara Major. 10 During that hearing, Judge Major explained the above maximum and mandatory minimum 11 sentences for the crime to which he was pleading guilty, and Lucas stated that he 12 understood. [Doc. No. 124 at 7-8.] Lucas told Judge Major that he had had enough time 13 with his counsel to discuss the plea agreement before signing it, that his counsel had 14 explained each and every term and condition and answered all of his questions, and that he 15 was satisfied with the representation he had received from his lawyer. [Id. at 11.] 16 Lucas was then sentenced by this Court on October 16, 2019. The pre-sentence 17 report recommended a sentence of 240 months with 20 years of supervised release. [Doc. 18 No. 104 at 13, 22.] The government requested a sentence of 240 months with 5 years of 19 supervised release. [Doc. No. 106 at 9.] Lucas’s counsel, Keith Rutman, recommended a 20 sentence of 160 months with 5 years of supervised release in his sentencing summary chart 21 [Doc. No. 112 at 1], and 180 months at the sentencing hearing [Doc. No. 121 at 5]. The 22 Court sentenced Lucas to 180 months with 5 years of supervised release. [Doc. Nos. 113, 23 114.] 24 25 26 27 28 1 II. Legal Standard 2 Defendant's motion to vacate his sentence arises under 28 U.S.C. § 2255, which 3 provides: 4 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 5 imposed in violation of the Constitution or laws of the United States, or that 6 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 7 subject to collateral attack, may move the court which imposed the sentence 8 to vacate, set aside or correct the sentence.

9 28 U.S.C. § 2255(a). Thus, “[u]nder 28 U.S.C. § 2255, a federal court may vacate, set 10 aside, or correct a federal prisoner’s sentence if the sentence was imposed in violation of 11 the Constitution or laws of the United States.” United States v. Withers, 638 F.3d 1055, 12 1062 (9th Cir. 2011). 13 III. Discussion 14 In his motion, Lucas contends that he would not have entered into his plea agreement 15 if not for ineffective assistance from his counsel. “A guilty plea is not knowingly and 16 voluntarily made if it was the result of ineffective assistance of counsel under ‘the two-part 17 Strickland v. Washington test.” United States v. Silveira, 997 F.3d 911, 913 (9th Cir. 2021) 18 (quoting Hill v. Lockhart, 474 U.S. 52, 56–58 (1985)). Under Strickland v. Washington, 19 “a defendant must show that counsel’s performance was deficient and that the deficient 20 performance prejudiced the defense.” Strickland v. Washington, 466 U.S. 668, 687 (1984). 21 Applied to a guilty plea, a defendant must “show (1) that his counsel’s advice to plead 22 guilty was not within the range of competence demanded of attorneys in criminal cases; 23 and (2) that there is a reasonable probability that, but for counsel’s errors, he would not 24 have pleaded guilty and would have insisted on going to trial.” Silveira, 997 F.3d at 913- 25 14 (internal citations and quotation marks omitted). 26 “The proper measure of attorney performance remains simply reasonableness under 27 prevailing professional norms,” and “the performance inquiry must be whether counsel’s 28 1 assistance was reasonable considering all the circumstances.” Id. at 688. Judicial scrutiny 2 of defense counsel’s performance must be “highly deferential,” and a court “must indulge 3 a strong presumption that counsel’s conduct falls within the wide range of reasonable 4 professional assistance. . . .” Id. at 689. 5 Moreover, “[a]n error by counsel, even if professionally unreasonable, does not 6 warrant setting aside the judgment of a criminal proceeding if the error had no effect on 7 the judgment.” Id. at 691. “The defendant must show that there is a reasonable probability 8 that, but for counsel’s unprofessional errors, the result of the proceeding would have been 9 different. A reasonable probability is a probability sufficient to undermine confidence in 10 the outcome.” Id. at 694. Thus, 11 “Surmounting Strickland’s high bar is never an easy task,” Padilla v. Kentucky, 559 U.S. 356, 371 (2010), and the strong societal interest in finality 12 has “special force with respect to convictions based on guilty pleas.” United 13 States v. Timmreck, 441 U.S. 780, 784 (1979). Courts should not upset a plea solely because of post hoc assertions from a defendant about how he would 14 have pleaded but for his attorney’s deficiencies. Judges should instead look 15 to contemporaneous evidence to substantiate a defendant’s expressed preferences. 16

17 Lee v. United States, 137 S. Ct. 1958, 1967 (2017).

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Related

Padilla v. Kentucky
559 U.S. 356 (Supreme Court, 2010)
United States v. Timmreck
441 U.S. 780 (Supreme Court, 1979)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Hill v. Lockhart
474 U.S. 52 (Supreme Court, 1985)
Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
Jae Lee v. United States
582 U.S. 357 (Supreme Court, 2017)
United States v. Ernest Glover
872 F.3d 625 (D.C. Circuit, 2017)
United States v. Gregory Silveira
997 F.3d 911 (Ninth Circuit, 2021)
United States v. Withers
638 F.3d 1055 (Ninth Circuit, 2010)

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Lucas v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lucas-v-united-states-casd-2021.