Merriweather v. United States

CourtDistrict Court, S.D. Illinois
DecidedMay 31, 2022
Docket3:19-cv-01268
StatusUnknown

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

Bluebook
Merriweather v. United States, (S.D. Ill. 2022).

Opinion

UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS

JEROME MERRIWEATHER,

Petitioner,

v. Civil No. 19-cv-1268-JPG Criminal No 15-cr-40046-JPG-006 UNITED STATES OF AMERICA,

Respondent.

MEMORANDUM AND ORDER This matter comes before the Court on petitioner Jerome Merriweather’s motion to vacate, set aside or correct his sentence pursuant to 28 U.S.C. § 2255 (Doc. 1). Pursuant to the Court’s instruction, the Government has responded to Grounds 1.a and 1.c of the motion (Doc. 11), and Merriweather has replied to that response (Doc. 14). The Court also addresses Merriweather’s motion for leave to amend his § 2255 motion (Doc. 15), to which the Government has not responded. I. Background In October 2015, a grand jury indicted Merriweather on one count of conspiracy to distribute 100 grams or more of heroin in violation of 21 U.S.C. § 841(a) and (b)(1)(B) and on three counts of distribution of heroin in violation of 21 U.S.C. § 841(a) and (b)(1)(C). Represented by attorney Cheryl R. Whitley, on April 7, 2016, Merriweather pled guilty to all four counts pursuant to a written plea agreement accompanied by a stipulation of facts. Prior to accepting the plea, the Court conducted a plea colloquy that substantially complied with Federal Rule of Criminal Procedure 11. During the plea hearing, it was noted that it was not clear whether Merriweather would qualify as a career offender. After the plea but prior to sentencing, the Court allowed Whitley to withdraw as counsel and appointed new counsel (twice) to represent Merriweather. Following an initial presentence investigation report finding Merriweather was, indeed, a career offender, Merriweather, then represented by John D. Stobbs, moved to withdraw his guilty plea to all four counts. After holding a hearing on the matter on April 26, 2017, the Court denied the motion. At the August 1, 2017, sentencing hearing, the Court found Merriweather to be a career

offender and sentenced him to serve 228 months in prison on each count, all to run concurrently. Merriweather appealed his conviction to the United States Court of Appeals for the Seventh Circuit, which on November 20, 2018, dismissed the appeal after allowing appellate counsel to withdraw pursuant to Anders v. California, 386 U.S. 738 (1967). See United States v. Merriweather, 743 F. App’x 31 (7th Cir. 2018). Merriweather did not seek a writ of certiorari from the Supreme Court. The Court will set forth additional facts as necessary in its discussion of the claims Merriweather raises in his § 2255 motion. II. § 2255 Motion

In his timely § 2255 motion, the petitioner makes a number of arguments. Pursuant to Rule 4(b) of the Rules Governing Section 2255 Proceedings for the United States District Courts, the Court disposed of some of the grounds for relief Merriweather asserts, and directed the Government to respond only to Grounds 1.a and 1.c: Ground 1.a: Whitley was constitutionally ineffective in violation of his Sixth Amendment rights because she misled him into pleading guilty by falsely promising he would receive a furlough to obtain necessary surgery, and even though Merriweather told her the factual basis for the plea was incorrect and he was actually innocent of the charges and, as a consequence, Merriweather’s plea was not knowing and voluntary; and

Ground 1.c: Stobbs failed to argue in the motion to withdraw Merriweather’s guilty plea that he was innocent of the crimes to which he had pled guilty, 2 instead making the weak argument that the plea agreement was an improper contract of adhesion to which Merriweather should not be bound.

These are the only remaining potential grounds for § 2255 relief. III. Analysis In its preliminary review order, the Court set forth the standards for § 2255 relief based on ineffective assistance of counsel: The Court must grant a § 2255 motion when a defendant’s “sentence was imposed in violation of the Constitution or laws of the United States.” 28 U.S.C. § 2255(a). However, “[r]elief under § 2255 is available ‘only in extraordinary situations, such as an error of constitutional or jurisdictional magnitude or where a fundamental defect has occurred which results in a complete miscarriage of justice.’” United States v. Coleman, 763 F.3d 706, 708 (7th Cir. 2014) (quoting Blake v. United States, 723 F.3d 870, 878-79 (7th Cir. 2013)). It is proper to deny a § 2255 motion without an evidentiary hearing if “the motion and the files and records of the case conclusively demonstrate that the prisoner is entitled to no relief.” 28 U.S.C. § 2255(b); see Shipman v. United States, 925 F.3d 938, 943 (7th Cir. 2019); Sandoval v. United States, 574 F.3d 847, 850 (7th Cir. 2009). * * * The Sixth Amendment to the Constitution provides that “[i]n all criminal prosecutions, the accused shall enjoy the right . . . to have the Assistance of Counsel for his defence.” U.S. Const. amend. VI. This right to assistance of counsel encompasses the right to effective assistance of counsel. McMann v. Richardson, 397 U.S. 759, 771, n. 14 (1970); Watson v. Anglin, 560 F.3d 687, 690 (7th Cir. 2009). A party claiming ineffective assistance of counsel bears the burden of showing (1) that his counsel’s performance fell below objective standards for reasonably effective representation and (2) that this deficiency prejudiced the defense. Strickland v. Washington, 466 U.S. 668, 688-94 (1984); Groves v. United States, 755 F.3d 588, 591 (7th Cir. 2014). To satisfy the first prong of the Strickland test, the petitioner must direct the Court to specific acts or omissions of his counsel. Wyatt v. United States, 574 F.3d 455, 458 (7th Cir. 2009). The Court must then consider whether, in light of all of the circumstances, counsel’s performance was outside the wide range of professionally competent assistance. Id. To satisfy the second prong of the Strickland test, the plaintiff “must demonstrate ‘a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different. A reasonable probability is a probability sufficient to undermine confidence in the outcome.’” Harrington v. Richter, 562 U.S. 86, 104 (2011) (quoting Strickland, 466 U.S. at 694); accord Groves, 755 F.3d at 591. 3 Mem. & Order 3-4 (Doc. 2). The Court now turns to the two claimed instances of ineffective assistance of counsel by Whitley and Stobbs. A. Whitley In Ground 1.a, Merriweather faults Whitley for inducing him to plead guilty with a false promise that he would receive a furlough for surgery for his gunshot wound even though at the time he had told her that the factual basis for his plea was incorrect and that he was actually innocent of the conspiracy. Where a defendant pled guilty as a result of alleged ineffective assistance of counsel, to

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Merriweather v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/merriweather-v-united-states-ilsd-2022.