Lumpkin v. United States

CourtDistrict Court, M.D. Tennessee
DecidedSeptember 3, 2019
Docket3:16-cv-01473
StatusUnknown

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

Bluebook
Lumpkin v. United States, (M.D. Tenn. 2019).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION

RICHARD ALLEN LUMPKIN, ) ) Movant, ) ) v. ) Case No. 3:16-cv-01473 ) Judge Aleta A. Trauger UNITED STATES OF AMERICA, ) ) Respondent. )

MEMORANDUM & ORDER

Before the court is Richard Lumpkin’s Motion to Vacate, Set Aside, or Correct Sentence in Accordance with 28 U.S.C. § 2255. (Doc. No. 1.) Lumpkin seeks to vacate and reduce the sentence entered upon his criminal conviction in United States v. Lumpkin, No. 3:95-cr-00065 (M.D. Tenn. Apr. 12, 1996) (Morton, J.), under Johnson v. United States, 135 S. Ct. 2551 (2015), which invalidated the so-called “residual clause” of the Armed Career Criminal Act (“ACCA”), 18 U.S.C. § 924(e). As set forth herein, the court finds that Johnson does not apply to Lumpkin’s claim and that the motion must be denied as time-barred. I. Procedural Background Lumpkin was sentenced in April 1996 to a prison term of 405 months following his guilty plea to two counts of possession with intent to distribute methamphetamine, in violation of 18 U.S.C. § 841(a)(1). The Sixth Circuit affirmed. United States v. Lumpkin, 159 F.3d 983 (6th Cir. 1998). Lumpkin’s initial motion under § 2255 was denied, Lumpkin v. United States, No. 3:00-cv-00048 (M.D. Tenn. Jan. 10, 2001) (Campbell, J.), and the Sixth Circuit denied a certificate of appealability, Lumpkin v. United States, No. 01-5229 (6th Cir. Dec. 27, 2001). On June 20, 2016, Lumpkin filed his present Motion to Vacate, arguing that his sentencing range was calculated based on his classification as a career offender under the United States Sentencing Guidelines, under a clause of the guidelines identical to the statutory provision held to be unconstitutionally vague in Johnson.1 Consideration of the Motion was stayed pending the Sixth Circuit’s review of Lumpkin’s application to file a second or successive petition. (Doc. No. 6.) After the appellate court granted that application on October 4, 2016 (see Doc. No. 7),

Lumpkin filed a Supplemental Brief (Doc. No. 10), asking the court to postpone ruling on his motion until the “potential rehearing process” had been completed for Raybon v. United States, 867 F.3d 625 (6th Cir. 2017). He expressly acknowledges therein that Raybon precludes the relief sought and that, unless the Sixth Circuit reversed course en banc, his motion must be deemed time-barred. (See Doc. No. 10, at 7.) In its Response, the United States argues that the movant has not asserted a right newly recognized by the Supreme Court and made retroactively applicable to cases on collateral review, 28 U.S.C. § 2255(f)(3), and, therefore, that his motion is time-barred. (Doc. No. 12 (citing Raybon, 867 F.3d at 629–30).) Lumpkin thereafter filed a pro se Reply (Doc. No. 13).

II. Standard of Review 28 U.S.C. § 2255 provides a statutory mechanism for a post-conviction challenge to the imposition of a federal sentence. In order to obtain relief under § 2255, a movant “‘must

1 The Presentence Report (“PSR”) does not expressly identify what prior convictions the Probation Office included for purposes of characterizing Lumpkin as a career offender. It simply lists his prior convictions and then, under “Criminal History Computation,” states that, although the “total of the criminal history points is 9, which establishes a criminal history category of IV, . . . the defendant is a career offender since the instant offense is a controlled substance offense and the defendant has at least two prior felony convictions of either a crime of violence or a controlled substance offense.” (PSR at 10– 11.) Because he was a career offender, his criminal history category was automatically VI. (Id. at 11 (citing U.S.S.G. § 4B1.1).) As Lumpkin noted in the present Motion, “[a]though the [PSR] does not so state, it appears that his offense level on his drug count was higher than the career offender range, but that his criminal history category was increased from a IV to a VI by application of the career offender guideline,” which increased his sentencing range. (Doc. No. 1, at 2.) In its Response, the United States does not contest the implication that the career offender guideline only applied based on prior burglary convictions that would no longer qualify as crimes of violence except under the residual clause of the career offender guideline, § 4B1.2(1)(ii) (1994). demonstrate the existence of an error of constitutional magnitude which had a substantial and injurious effect or influence on the guilty plea or the jury’s verdict.’” Humphress v. United States, 398 F.3d 855, 858 (6th Cir. 2005) (quoting Griffin v. United States, 330 F.3d 733, 736 (6th Cir. 2003)). A motion under § 2255 is subject to a one-year statute of limitations. 28 U.S.C. § 2255(f).

The one-year period runs from “the latest of” four possible events, only two of which are relevant here: (1) the date on which the judgment of conviction becomes final; [or] (3) the date on which the right asserted was initially recognized by the Supreme Court, if that right has been newly recognized by the Supreme Court and made retroactively applicable to cases on collateral review . . . . Id. § 2255(f)(1), (3). Because his conviction became final more than twenty years ago, the current motion is clearly time-barred if subsection (1) is the latest relevant event. Lumpkin claims that he is entitled to relief under subsection (3), because Johnson articulated a newly recognized right made retroactive on collateral review. III. Analysis In Johnson, the Supreme Court held that the subsection of the ACCA that included within the scope of the definition of “violent felony” any crime that “involves conduct that presents a serious potential risk of physical injury to another,” 18 U.S.C. § 924(e)(2)(B)(ii)—the so-called “residual clause”—was unconstitutionally vague and, therefore, that “an increased sentence under the residual clause . . . violates the Constitution’s guarantee of due process.” Johnson, 135 S. Ct. at 2555–56. That holding was made retroactive to cases on collateral review by the Supreme Court’s decision in Welch v. United States, 136 S. Ct. 1257 (2016). Lumpkin was not sentenced under the ACCA. He nonetheless argues that his sentencing guideline range calculation—and therefore his sentence—was defective, because the definitional language in the “career offender” guideline, U.S.S.G. § 4B1.2(1)(ii) (1994), encompassing “any offense” that “otherwise involves conduct that presents a serious potential risk of physical injury to another,” is nearly identical to the ACCA’s residual clause found unconstitutional in Johnson. Indeed, the Sixth Circuit held on May 13, 2016 that the Johnson rationale applied with equal force to the residual clause in U.S.S.G. § 4B1.2, compelling the conclusion that the residual

clause of § 4B1.2 is also unconstitutionally vague. United States v.

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Related

United States v. Booker
543 U.S. 220 (Supreme Court, 2004)
United States v. Richard Allen Lumpkin
159 F.3d 983 (Sixth Circuit, 1998)
Phillip Griffin v. United States
330 F.3d 733 (Sixth Circuit, 2003)
Jackie Humphress v. United States
398 F.3d 855 (Sixth Circuit, 2005)
Johnson v. United States
576 U.S. 591 (Supreme Court, 2015)
Welch v. United States
578 U.S. 120 (Supreme Court, 2016)
United States v. Jesse Pawlak
822 F.3d 902 (Sixth Circuit, 2016)
Jerome Raybon v. United States
867 F.3d 625 (Sixth Circuit, 2017)
Beckles v. United States
580 U.S. 256 (Supreme Court, 2017)

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Bluebook (online)
Lumpkin v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lumpkin-v-united-states-tnmd-2019.