Mejia v. USA

2001 DNH 084
CourtDistrict Court, D. New Hampshire
DecidedApril 30, 2001
DocketCV-01-104-M
StatusPublished
Cited by1 cases

This text of 2001 DNH 084 (Mejia v. USA) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mejia v. USA, 2001 DNH 084 (D.N.H. 2001).

Opinion

Mejia v . USA CV-01-104-M 04/30/01 UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

Alfredo Luis Mejia, Petitioner

v. Civil N o . 01-104-M Opinion N o . 2001 DNH 084 United States of America, Respondent

O R D E R

Petitioner, Alfredo Mejia, seeks to vacate his conviction

for violating various federal drug laws, asserting that the

indictment in his underlying criminal case was constitutionally

defective. Specifically, he says that in light of the Supreme

Court’s opinion in Apprendi v . New Jersey, 530 U.S. 466 (2000),

the indictment was required (but failed) to include: (1) the

quantity of crack cocaine he was accused of possessing and/or

distributing; and (2) a reference to the pertinent federal

statute(s) imposing the penalties for the crimes with which he

was charged. Because the record conclusively reveals that he is

entitled to no relief, his petition is denied. See 28 U.S.C.

§ 2255. Background

On November 7 , 1995, Mejia pled guilty to seven counts of a

superceding indictment charging him with violations of federal

drug laws: one count of conspiracy to distribute and to possess

with the intent to distribute cocaine and cocaine base (also

known as “crack”); and six counts of unlawful distribution of

cocaine and cocaine base. On February 6, 1996, the court

sentenced Mejia to 120 months of incarceration, followed by a

five year term of supervised release.

Pursuant to 28 U.S.C. § 2255, Mejia then sought habeas

corpus relief, saying the government breached the terms of his

plea agreement and claiming his appointed counsel provided

ineffective assistance in violation of his Sixth Amendment

rights. The court concluded that Mejia was not entitled to

relief on either ground, with one possible exception:

Petitioner’s ineffective assistance claim can fairly be read to include a claim that the Guideline Sentencing Range calculation was incorrect, because drug quantities, related to “relevant conduct” that occurred prior to the conspiracy offense charged in Count I , were improperly used to determine the ten year mandatory minimum sentence applicable to Count I . That ten year mandatory minimum resulted in a GSR (Total Offense Level 2 9 , Criminal History Category I ) of 120

2 to 121 months of imprisonment. It appears that the mandatory minimum sentence applicable to Count I (based only on drug quantities relevant to the offense of conviction) should have been 5 years, not ten (i.e. excluding the pre-conspiracy relevant conduct drug quantity). Thus, the GSR should have been 97 to 121 months, not 120 to 121 months.

Mejia v . United States, Civil N o . 97-424-M, at 1-2 (D.N.H. Jan.

2 9 , 1998). Accordingly, the court ordered that notice of the

petition be served upon the United States Attorney and directed

that h e ,

respond on or before February 2 0 , 1998, advising the court as to the government’s position relative to the court’s intention to grant relief by correcting petitioner’s sentence to imprisonment, that i s , reducing it from 120 months to the lowest point in the applicable guideline range (97 months), thereby insuring that no prejudice results from the apparent calculation error.

Id. at 2 . The government responded, saying that it did not

object to the court’s proposal to resentence Mejia to 97 months

of incarceration. On February 2 7 , 1998, the court granted

Mejia’s petition to vacate his sentence, resentenced him to a 97

month term of imprisonment, and reimposed a 5-year term of

3 supervised release.1 On March 2 1 , 2001, Mejia filed the petition

for habeas corpus relief currently before the court.

Discussion

I. Second or Successive Petitions for Habeas Relief.

Under 28 U.S.C. § 2255, as amended by the Antiterrorism and

Effective Death Penalty Act (“AEDPA”), a federal inmate may file

1 It appears that the term of supervised release imposed on Mejia was in excess of that permitted by law and that he should have been sentenced to no more than three years of supervised release. See U.S.S.G. § 5D1.2 (Nov. 1 , 1995). That error was the product of an incorrect interpretation of the applicable Sentencing Guidelines that affected a significant number of defendants sentenced in this district during a particular time period, rather than any Apprendi issue. Although Mejia has not raised that issue in his petition, it will be remedied in due course anyway. This court has taken steps to insure that the term of supervised release imposed on Mejia and other affected defendants is correct. When it was discovered that a number of criminal defendants had erroneously been sentenced to terms of supervised release in excess of those provided by 21 U.S.C. § 841(b)(1)(C) and U.S.S.G. § 5D1.2, the judges of this court issued procedural orders to all affected parties. Each affected defendant was notified of the error and told that at least two weeks prior to his or her release from prison, the United States Probation Office will file, and the court will grant, a request that the term of supervised release imposed on the defendant be reduced to a level consistent with the applicable Guideline requirements (in this case from five years to three years). Thus, the error concerning Mejia’s term of supervised release will be corrected before he begins serving that aspect of his sentence.

4 a second or successive § 2255 petition only if the court of

appeals first certifies that the petition is based on either:

(1) newly discovered evidence that, if proved and viewed in light of the evidence as a whole, would be sufficient to establish by clear and convincing evidence that no reasonable factfinder would have found the movant guilty of the offense; or

(2) a new rule of constitutional law, made retroactive to cases on collateral review by the Supreme Court, that was previously unavailable.

28 U.S.C. § 2255. “This statutory directive means that a

district court, faced with an unapproved second or successive

habeas petition, must either dismiss i t , or transfer it to the

appropriate court of appeals.” Pratt v . United States, 129 F.3d

5 4 , 57 (1st Cir. 1997) (citations omitted). 2

Anticipating that his request for relief might constitute a

second or successive habeas corpus petition and seeking to avoid

2 Of course, not every historically second or successive habeas corpus petition is necessarily “second or successive” for purposes of § 2255. See generally Sustache-Rivera v . United States, 221 F.3d 8 , 12-13 (1st Cir. 2000) (discussing several circumstances in which a subsequent petition for habeas corpus relief is not deemed “second or successive” under § 2255), cert. denied, 121 S.Ct. 1364 (2001). As discussed more fully below, however, it is not entirely clear whether Mejia’s petition falls within the bounds of any arguably applicable exception(s).

5 the requirements applicable to such petitions under § 2255, Mejia

asserts that his current petition for habeas relief is brought

pursuant to 28 U.S.C.

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