Michael Moore v. United States of America

CourtDistrict Court, M.D. Florida
DecidedNovember 18, 2025
Docket8:22-cv-01415
StatusUnknown

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

Bluebook
Michael Moore v. United States of America, (M.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION

MICHAEL MOORE,

Petitioner,

v. Case No. 8:22-cv-1415-CEH-CPT Crim. Case No. 8:17-cr-354-CEH-CPT

UNITED STATES OF AMERICA,

Respondent. /

ORDER Before the Court is Michael Moore’s motion to vacate, set aside, or correct his sentence under 28 U.S.C. § 2255 (Doc. 1) and memorandum in support (Doc. 2). The United States filed a response in opposition. (Doc. 18). Moore filed a reply (Doc. 20) and a supplement to his § 2255 motion (Doc. 4). Also before the Court are Moore’s two identical motions to supplement further his § 2255 motion (Docs. 21, 22), to which the United States responded (Doc. 24), and Moore filed a reply (Doc. 26). Moore’s motions to supplement his § 2255 motion and his § 2255 motion are due to be denied.1

I. BACKGROUND AND PROCEDURAL HISTORY

1 The motion can be denied without need for an evidentiary hearing, as no hearing is required when the record establishes that a Section 2255 claim lacks merit. See United States v. Lagrone, 727 F.2d 1037, 1038 (11th Cir. 1984). Moore was charged with possession of a firearm and ammunition by a felon, in violation of 18 U.S.C. §§ 922(g)(1) and 924(e). (Cr-Doc. 1).2 The indictment listed Moore’s prior felony convictions, including two 2008 convictions for possession of

cocaine, and a 2005 conviction for sale of cocaine, all in violation of § 893.13, Florida Statutes. (Id. at 2). Moore was found guilty as charged after a jury trial, and this Court then adjudicated him guilty. (Cr-Docs. 76, 79). Before sentencing, the United States Probation Office prepared a Presentence Investigation Report (PSR), in which it set Moore’s base offense level at 24 under

USSG §2K2.1 because he had committed the firearm offense after sustaining two felony convictions for a “controlled substance offense.” (Cr-Doc. 93 at 7, ¶ 23).3 And because he had at least three prior convictions for a “serious drug offense” under the Armed Career Criminal Act (“ACCA”), 18 U.S.C. § 924(e),—his cocaine-related offenses—he was subject to an armed career criminal enhancement under USSG

2 References to filings in Moore’s criminal case, Case No.: 8:17-cr-354-CEH-CPT, are cited throughout this Order as “Cr-Doc. [document number].”

3 For a defendant convicted of the unlawful possession of a firearm, section 2K2.1(a)(2) sets a base offense level 24 “if the defendant committed any part of the instant offense subsequent to sustaining at least two felony convictions of either a crime of violence or a controlled substance offense.” USSG §2K2.1(a)(2). Section 2K2.1 refers to the career-offender guideline in USSG §4B1.2, which defines a “controlled substance offense” as “an offense under federal or state law, punishable by imprisonment for a term exceeding one year, that prohibits the manufacture, import, export, distribution, or dispensing of a controlled substance . . . or the possession of a controlled substance . . . with intent to manufacture, import, export, distribute, or dispense.” USSG §§2K2.1, cmt. (n.1), 4B1.2(b). §4B1.4 and a minimum sentence of 15 years’ imprisonment. (Id. ¶¶ 29, 100; see also id. at 30–55).4 Moore objected to the ACCA enhancement, asserting that the United States

would not be able to produce documentation to prove the predicate offenses. (Id. at 27; see also Cr-Doc. 98 at 2, 5–8; Cr-Doc. 115 at 6–9). He also asserted that his crimes for possession of cocaine with intent to sell or deliver did not qualify as “serious drug offenses” because the offenses did not require that he receive remuneration or know

the illicit nature of the controlled substance. (Id.). Additionally, Moore argued that he was entitled to an offense level reduction for acceptance of responsibility, despite his decision to proceed to a jury trial. (Cr-Doc. 115 at 15–21). This Court overruled Moore’s objections and found that his four prior felony convictions—sale of cocaine on November 16, 2004, sale of rock cocaine on October

11, 2005, and possession of cocaine with intent to sell or deliver on December 19, 2006 and February 18, 2006—constituted “serious drug offenses” under the ACCA and qualified him for the § 4B1.4 enhancement. (Id. at 14–15, 20–21). Moore’s increased total offense level of 33 and his criminal history category VI resulted in a guidelines range of 235 to 293 months’ imprisonment, followed by two to five years’ supervised

4 Under the ACCA, a defendant convicted of a § 922(g) offense faces a 15-year minimum sentence and a maximum term of life imprisonment if he has three prior convictions for a “violent felony,” a “serious drug offense,” or a combination of both, “committed on occasions different from one another.” 18 U.S.C. § 924(e)(1). Moore committed the predicate offenses of sale of cocaine on November 16, 2004, sale of rock cocaine on October 11, 2005, and possession of cocaine with intent to sell or deliver on December 19, 2006, and again on February 18, 2006. (Cr-Doc. 93 ¶¶ 29, 100). release. (Id. at 22). After considering the section 3553(a) factors, this Court sentenced Moore to a below-guidelines sentence of 188 months’ imprisonment, followed by five years’ supervised release. (Id. at 41; see also Cr-Doc. 103).

On direct appeal, Moore argued that this Court “erred in denying him an acceptance-of-responsibility reduction” and “erroneously believed it lacked the authority to give a reduction,” and that his prior Florida cocaine-related convictions did not qualify as “serious drug offenses” under the ACCA. See United States v. Moore,

814 F. App’x 465, 466 (11th Cir. 2020). The Eleventh Circuit ruled that this Court “did not clearly err in finding Moore did not meet his burden of showing he clearly accepted responsibility for his offense” and “understood its discretion in granting or denying a reduction.” Id. at 467–68. The court then rejected Moore’s ACCA challenge, finding it was foreclosed by United States v. Smith, 775 F.3d 1262 (11th Cir. 2014), in

which it had “also analyzed and rejected the necessity of a mens rea element in the underlying crime to qualify as a serious drug offense under the ACCA.” Id. at 468. The Eleventh Circuit affirmed Moore’s sentence. Id. Moore then petitioned for a writ of certiorari with the Supreme Court, which was denied. (Cr-Doc. 124). Moore’s § 2255 motion raises three claims for relief in reliance on United States

v. Jackson, 36 F.4th 1294 (11th Cir. 2022) (“Jackson”)—that his prior Florida cocaine- related convictions no longer qualify as “serious drug offenses” under the ACCA and thus he is “actually innocent” of the armed career offender enhancement (Grounds One and Two) and that his attorney was ineffective for failing to raise that argument with this Court (Ground Four). (Doc. 1 at 4–5, 8, 12). He also claims his armed career offender designation is invalid in light of Borden v. United States, 141 S. Ct. 1817 (2021). (Id. at 6). The United States moved to stay the § 2255 proceedings pending the issuance

of the Eleventh Circuit’s mandate in Jackson, and this Court granted the motion. (Docs. 7, 8). After the Eleventh Circuit entered a superseding decision in United States v.

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