Martinez v. United States

District Court, N.D. Texas·Decided December 21, 2023·No. 3:21-cv-00563·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

JOSUE EMMANUEL MARTINEZ, § § Petitioner, § § v. § Civil Action No. 3:21-CV-563-L-BH § Criminal No. 3:17-CR-545-L-1 UNITED STATES OF AMERICA, § § Respondent. §

MEMORANDUM OPINION AND ORDER

On November 6, 2023, the Findings, Conclusions and Recommendation of the United States Magistrate Judge (“Report”) (Doc. 17) was entered, recommending that the court deny with prejudice Petitioner’s Motion Under 28 U.S.C. § 2255 to Vacate, Set Aside, or Correct Sentence by a Person in Federal Custody (Doc. 2) and dismiss with prejudice his four habeas claims,1 based on the alleged ineffective assistance of trial and appellate counsel, because Petitioner failed to satisfy both prongs of Strickland v. Washington, 466 U.S. 668 (1984). In addition, the magistrate judge determined that Petitioner’s habeas claim based on the voluntariness of his guilty plea failed because he has not shown that his guilty plea was involuntary or that he was unaware of the consequences of pleading guilty. Petitioner filed objections to the Report (Doc. 21) in which he asserts his disagreement with the magistrate judge’s determinations. Specifically, with respect to his first claim, he disagrees that he has not established prejudice. He also disagrees that he has only offered conclusory, self-serving allegations of prejudice. For support, he cites to extensive legal authority

1 Petitioner’s four ineffective assistance of counsel claims are based on counsel’s alleged: (1) failure to explain the mens rea element of offense; (2) failure to investigate possible defenses; and (3) and failure to appeal based on the holding in Rehaif v. United States, 139 S. Ct. 2191 (2019). and contends that, “even undisputed guilty have a Sixth Amendment right,” and “[t]he paramount importance of vigorous representation follows from the nature of our adversarial system of justice.” Obj. 4. The court agrees with the magistrate judge that Petitioner’s assertions of prejudice are conclusory and unsupported. Further, his legalistic objection is insufficient to establish

prejudice. While Petitioner also continues to maintain that trial counsel was ineffective for failing to explain an element of the offense, this does not address the magistrate judge’s determination regarding the prejudice prong of Strickland. Regarding his second claim, Petitioner again disagrees with the magistrate judge’s determination that he failed to show that he was prejudiced as required by Strickland. He similarly contends with respect to this claim, that he had an “unalienable right under the Sixth Amendment to have his case fully investigated.” Obj. 9. This objection fails for the same reason his objection regarding his first claim fails, as it does not provide anything other than a conclusory, legalistic argument that does not address the magistrate judge’s lack of prejudice determination. Regarding his claim based on the voluntariness of his guilty plea, the magistrate judge

determined that Petitioner’s Rehaif argument: (1) failed with respect to his underlying criminal conviction because he had not satisfied both Strickland prongs; and (2) failed with respect to his revocation because it was barred by the statute of limitations, and he had not provided any basis for equitable tolling. Petitioner objects to the magistrate judge’s Strickland determination, contending that the Government failed to prove that he is a prohibited person for purposes of 18 U.S.C. § 922(g)(1). This argument, however, does not resolve the deficiency identified by the magistrate judge. In addition, he contends for the first time that he was actually innocent of the offense because he had a right to possess a firearm under New York State Rifle & Pistol Association, Incorporated v. Bruen, 142 S. Ct. 2111 (2022). Petitioner appears to argue that, as a result of Bruen and the new test adopted by the Supreme Court in that case, § 922(g)(1) violates the Second Amendment. No argument based on Bruen was not previously presented to the magistrate judge. Even assuming that this argument was not waived by failure to present it to the magistrate judge,

it fails for other reasons. Petitioner’s reliance on Bruen does not relieve him of satisfying Strickland’s requirements, and his assertion of actual innocence based on Bruen and Rehaif is conclusory and not supported by any facts or evidence. Additionally, Bruen did not involve a challenge to 18 U.S.C. § 922(g)(1), and the Fifth Circuit has consistently upheld the constitutionality of § 922(g)(1).2 Thus, based on binding Fifth Circuit and Supreme Court precedent, the court disagrees that § 922(g)(1) violates the Second Amendment. Finally, Petitioner “objects to the Report’s conclusion regarding his guilty plea” and asserts that he “stands on his claims that trial counsel gas-lighted him and coerced him.” Obj. 13. He further asserts that, “because he is factually and actually innocent of his 18 U.S.C. § 922(g)(1) conviction, his plea of guilty should not stand.” Id. Like Petitioner’s other objections, this

argument is conclusory and unsupported, and the court determines that the magistrate judge’s determination as to this and Petitioner’s other claims is correct. Additionally, the Fifth Circuit has consistently upheld the constitutionality of 18 U.S.C. § 922(g)(1).

2 In United States v. Darrington, the Fifth Circuit observed that “legislative prohibitions on the ownership of firearms by felons are not considered infringements on the historically understood right to bear arms protected by the Second Amendment.” 351 F.3d 632, 634 (5th Cir. 2003). It thus held that “Section 922(g)(1) [did] not violate the Second Amendment.” Id. (citing United States v. Emerson, 270 F.3d 203, 226 n.21 (5th Cir. 2001)). In United States v. Anderson, 559 F.3d 348, 352 (5th Cir. 2009), the Fifth Circuit considered whether its holding in Darrington survived the Supreme Court’s decision in District of Columbia v. Heller, 554 U.S. 570 (2008), which invalidated the District of Columbia’s ban on individuals possessing handguns in their homes. Relying on Heller’s reasoning that “‘nothing in [its] opinion should be taken to cast doubt on longstanding prohibitions on the possession of firearms by felons,’” the Fifth Circuit in Anderson “reaffirm[ed] Darrington and the constitutionality of § 922(g).” Anderson, 559 F.3d at 352 & n.6 (quoting Heller, 554 U.S. at 626). In United States v. Scroggins, the Fifth Circuit once again reaffirmed Darrington and Anderson and reiterated “that criminal prohibitions on felons (violent or nonviolent) possessing firearms” did not violate the Second Amendment. 599 F.3d 433, 451 (5th Cir. 2010).

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Related

United States v. Emerson
270 F.3d 203 (Fifth Circuit, 2001)
United States v. Darrington
351 F.3d 632 (Fifth Circuit, 2003)
United States v. Scroggins
599 F.3d 433 (Fifth Circuit, 2010)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
District of Columbia v. Heller
554 U.S. 570 (Supreme Court, 2008)
United States v. Anderson
559 F.3d 348 (Fifth Circuit, 2009)
Rehaif v. United States
588 U.S. 225 (Supreme Court, 2019)