Marcus Antonio Grubbs v. United States of America

CourtDistrict Court, M.D. Alabama
DecidedMarch 30, 2026
Docket1:22-cv-00632
StatusUnknown

This text of Marcus Antonio Grubbs v. United States of America (Marcus Antonio Grubbs v. United States of America) 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
Marcus Antonio Grubbs v. United States of America, (M.D. Ala. 2026).

Opinion

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

MARCUS ANTONIO GRUBBS, ) ) Petitioner, ) ) v. ) CASE NO. 1:22-cv-632-ECM ) [WO] UNITED STATES OF AMERICA, ) ) Respondent. )

MEMORANDUM OPINION and ORDER

Marcus Antonio Grubbs (“Grubbs”), a federal inmate proceeding pro se, filed a motion pursuant to 28 U.S.C. § 2255 challenging his conviction in United States v. Grubbs, Case No. 1:20-cr-25-ECM.1 (Doc. 1). Upon review of the parties’ submissions and other relevant portions of the record in accordance with Rule 8(a) of the Rules Governing Section 2255 Proceedings, the Court concludes that an evidentiary hearing is not warranted and that Grubbs’ § 2255 motion is due to be DENIED and DISMISSED with prejudice. I. GRUBBS’ CRIMINAL PROCEEDINGS Grubbs was indicted in February 2020 on five firearm and controlled-substance offenses. (See Crim. Doc. 1). In September 2020, pursuant to a written plea agreement, Grubbs pleaded guilty to Count 2, possession of a stolen firearm in violation of 18 U.S.C. § 922(j); and Count 4, possession of a stolen firearm in furtherance of a drug trafficking crime in violation of 18 U.S.C. § 924(c). (Crim. Docs. 27, 28). In consideration of Grubbs’

1 All citations to the docket in this action will be denoted as “Doc.” All citations to the underlying criminal action will be denoted as “Crim Doc.” guilty plea, the Government agreed to move at sentencing for a one-level reduction in his offense level for acceptance of responsibility and for dismissal of the remaining three

counts in the indictment. (Crim. Doc. 27 at 2–3). Grubb’s plea agreement contained a waiver of “any and all rights . . . to appeal the conviction or sentence” and “the right to attack the conviction or sentence in any post-conviction proceeding, including proceedings pursuant to 28 U.S.C. § 2255,” except for claims based on ineffective assistance of counsel or prosecutorial misconduct. (Crim. Doc. 27 at 6–7). At the sentencing hearing, the Court granted the Government’s motion for a

reduction in Grubbs’ offense level for acceptance of responsibility, dismissed the remaining three counts in the Indictment, and sentenced Grubbs to 157 months’ imprisonment on Counts 2 and 4. Crim. Doc. 46. Grubbs timely appealed (Crim. Doc. 49), and the Eleventh Circuit affirmed based on the appeal waiver in his plea agreement, see United States v. Grubbs, 858 F. App’x 336 (11th Cir. 2021 (per curiam). Grubbs’ petition

for writ of certiorari to the United States Supreme Court was denied (Crim. Doc. 61), and he timely filed the instant § 2255 motion. II. GRUBBS’ § 2255 MOTION Grubbs’ § 2255 motion asserts one claim of ineffective assistance of counsel against Cecilia Vaca, who represented Grubbs from his initial arrest and arraignment through

sentencing. In an affidavit supporting his claims, Grubbs alleges he told Ms. Vaca that his confession and other incriminating statements were induced by threats from law enforcement to arrest his mother, uncle, and girlfriend; that his mother witnessed these threats; and that she was willing to testify about them. (Doc. 2 at 6–7). He further claims that Ms. Vaca did not contact his mother about his coerced confession or whether Grubbs was aware of the firearms and drugs in their homes. (Id. at 7). Thus, he contends Ms. Vaca

advised and assisted him into “falsely” pleading guilty without determining whether Grubbs “knowingly” possessed the firearms and drugs at issue. (Id.). Finally, Grubbs claims that, because he did not knowingly possess these items, if Ms. Vaca had not erroneously advised and assisted him, he would have gone to trial and “put the Government to its burden of proving that [he] ‘knowingly’ possessed the firearms and drugs found in my friends[’] and family members[’] homes.” (Id.) 2

Grubbs also filed an affidavit purportedly signed by his mother under penalty of perjury.3 (Doc. 2 at 9–10). She attests to having witnessed law enforcement’s threats to take her to jail if Grubbs did not confess to owning the firearms found at her house and his uncle’s house. (Id. at 9). She also states that Ms. Vaca never contacted her about the circumstances of Grubbs’ confession. (Id. at 10).

In response to Grubbs’ motion, Ms. Vaca filed an affidavit denying that she failed to investigate whether his confession was false or obtained in violation of the Fifth

2 In his memorandum supporting his petition, Grubbs asserts that Ms. Vaca did not investigate whether Grubbs knew he was barred from possessing firearms. (Doc. 2 at 2, para 3). In listing his convictions on his petition, Grubbs wrote, “Possession of a firearm by a convicted felon in furtherance of a drug trafficking crime.” (Doc. 1 at 1). Although Grubbs’ indictment included a charge for possession of a firearm by a convicted felon in violation of 18 U.S.C. § 922(g), Grubbs did not plead guilty to that charge. And even though this specific charge was not addressed at Grubbs’ plea hearing, Grubbs said he knew he was in possession of guns or that they were in his home and testified, “I just took the charge because I was a felon anyway with a gun.” (Crim. Doc. 56 at 18:4–14).

3 This affidavit is not notarized, and the signature on the affidavit is strikingly similar to Grubb’s signature on his motion and affidavit. (Compare doc. 1 at 13, with doc. 2 at 8, 10). Amendment and whether he had actual, constructive, or joint possession of the firearms and drugs found in his friends’ and relatives’ homes.4 (Doc. 7 at 2).

III. LEGAL STANDARD A. General Standard of Review Because collateral review is not a substitute for direct appeal, the grounds for collateral attack on final judgments under § 2255 are limited. A prisoner may obtain relief under § 2255 if the court imposed a sentence that (1) violated the Constitution 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); United States v. Walker, 198 F.3d 811, 813 n.5 (11th Cir. 1999). “[R]elief 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. Ineffective Assistance of Counsel Claims A claim of ineffective assistance of counsel is evaluated under the two-part test in Strickland v. Washington, 466 U.S. 668 (1984). An attorney is considered constitutionally ineffective if (1) his or her “performance was deficient” and (2) that “deficient performance

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Richard Joseph Lynn v. United States
365 F.3d 1225 (Eleventh Circuit, 2004)
Ward v. Hall
592 F.3d 1144 (Eleventh Circuit, 2010)
Blackledge v. Allison
431 U.S. 63 (Supreme Court, 1977)
Barefoot v. Estelle
463 U.S. 880 (Supreme Court, 1983)
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)
James Adams v. Louie L. Wainwright
709 F.2d 1443 (Eleventh Circuit, 1983)
David Ronald Chandler v. United States
218 F.3d 1305 (Eleventh Circuit, 2000)
United States v. Gary A. Phillips
225 F.3d 1198 (Eleventh Circuit, 2000)
Wilson Daniel Winthrop-Redin v. United States
767 F.3d 1210 (Eleventh Circuit, 2014)
Jae Lee v. United States
582 U.S. 357 (Supreme Court, 2017)
Nigel Christopher Paul Martin v. United States
949 F.3d 662 (Eleventh Circuit, 2020)

Cite This Page — Counsel Stack

Bluebook (online)
Marcus Antonio Grubbs v. United States of America, Counsel Stack Legal Research, https://law.counselstack.com/opinion/marcus-antonio-grubbs-v-united-states-of-america-almd-2026.