Michael Stephens v. United States of America

CourtDistrict Court, M.D. Florida
DecidedApril 7, 2026
Docket8:21-cv-02807
StatusUnknown

This text of Michael Stephens v. United States of America (Michael Stephens 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 Stephens v. United States of America, (M.D. Fla. 2026).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION

MICHAEL STEPHENS,

Movant,

v. Case No.: 8:21-cv-2807-CEH-CPT Crim. Case No. 8:18-cr-376-CEH-CPT

UNITED STATES OF AMERICA,

Respondent. /

ORDER Before the Court is Michael Stephens’s motion to vacate, set aside, or correct his sentence under 28 U.S.C. § 2255. (Doc. 1) The United States filed a response in opposition. (Doc. 13). Stephens did not file a reply, and the time frame for doing so has expired. (See Doc. 2 at 3). After reviewing the parties’ submissions and the record, the Court will deny the Section 2255 motion.1 I. STATEMENT OF FACTS2 Michael Stephens twice visited a Shooters World gun range location in September 2017, repeatedly firing a handgun on the range during both visits. (Cr-Doc. 52 at 2). Additionally, during one visit, Stephens purchased various types of

1 The motion can be denied without the 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).

2 The Statement of Facts derives from the United States’ Factual Basis. (Cr-Doc. 52 at 2–5). ammunition. (Id.). Several weeks later, he posted videos to Facebook of himself shooting a gun at Shooters World. (Id.). In April 2018, Stephens was with another individual in a car when he fired multiple rounds at another vehicle. (Id. at 3). Stephens

discarded the gun when law enforcement tried to stop the vehicle. (Id.). Law enforcement found the gun fully loaded with Stephens’s DNA on the trigger. (Id.). The firearms he possessed in September and April had traveled in interstate or international commerce. (Id. at 3–4). Before Stephens possessed the gun in September 2017, he had

been previously convicted of various felonies punishable by over one year in prison. (Id. at 4). II. BACKGROUND AND PROCEDURAL HISTORY Stephens was charged by indictment with possession of a firearm and ammunition by a previously convicted felon in violation of 18 U.S.C. §§ 922(g)(1) and

924(e)(1). (Cr-Doc. 13).3 Stephens faced an enhanced sentence under the Armed Career Criminal Act (“ACCA”) due to his prior convictions. (Id.). He pleaded guilty to both counts without a plea agreement. (Cr-Doc. 59). During the plea hearing, Stephens affirmed for the magistrate judge that he reviewed the facts with his counsel, that they had discussed Stephens’s options, and that he was “fully satisfied” with

counsel’s advice and representation. (Id. at 9). Stephens also affirmed that no one

3 References to filings in criminal case number 8:18-cr-376-CEH-CPT are cited as “Cr-Doc. [document number].” Pinpoint citations to electronically filed documents refer to the docket number followed by the page number that appears in the header generated by the court’s electronic filing system. threatened or promised him anything in exchange for his guilty plea. (Id. at 10). He acknowledged that he understood he faced a mandatory minimum 15-year sentence for each count. (Id. at 12). He also understood that he could not withdraw his guilty

plea if counsel’s sentencing estimate were incorrect. (Id. at 14–15). Stephens stated he had no questions about the charges or the elements of the offenses. (Id. at 16–19). After the United States recited the facts of the case, Stephens agreed that he possessed a firearm and ammunition on a specific date; that the gun

and ammunition previously traveled in interstate commerce; that he was previously convicted of a felony punishable by more than one year in prison; and that his civil rights were not restored before the firearm possession. (Id. at 20–24). Although Stephens agreed with the listed felony convictions, defense counsel wanted to “preserve any objections” to the ACCA enhancement. (Id. at 25). The magistrate judge

found a factual basis for the charges and determined that Stephens entered his guilty plea knowingly and voluntarily. (Id. at 29). This Court then adjudicated Stephens guilty. (Cr-Doc. 67). Stephens qualified as an Armed Career Criminal (“ACC”) based on three prior Florida convictions for: aggravated assault-firearm possession, possession of cocaine

with intent to sell or deliver, and delivery of cocaine. (Cr-Doc. 79 ¶¶ 23–24 (Presentence Investigation Report (“PSR”) dated June 26, 2019); see also Doc. 13, Attachment A (certified copies of convictions)). He faced an advisory guidelines range of 188 to 235 months’ imprisonment. (Id. ¶ 89). Stephens did not object to the PSR. (Id. at 28). At sentencing, this Court adopted the United States Probation Office’s guidelines calculation without objection from the parties. (Cr-Doc. 96 at 6). Relying on various mitigating factors, defense counsel asked for a 180-month sentence. (Id. at

10–11). This Court ultimately sentenced Stephens to serve 195 months in prison. (Cr- Doc. 85). Stephens did not pursue a direct appeal. In his Section 2255 motion, Stephens claims that he is actually innocent of his ACCA sentencing enhancement in light of the Supreme Court’s subsequent decision in Borden v. United States, 593 U.S. 420, 141 S. Ct. 1817, 210 L. Ed. 2d 63 (2021)

(Ground One). (See generally Doc. 1). Based on that decision, Stephens also claims that this Court lacked jurisdiction to impose the ACCA-enhanced sentence (Ground Two) and violated his due process rights (Ground Three). (See generally Doc. 1). This Court observes that Stephens moved to amend his Section 2255 motion to

include a claim that his prior Florida controlled-substance convictions do not support his ACCA enhancement in light of United States v. Jackson, 36 F.4th 1294 (11th Cir. 2022) (“Jackson I”), vacated, 2022 WL 4959314 (11th Cir. Sept. 8, 2022), superseded, 55 F.4th 846 (11th Cir. Dec. 13, 2022) (“Jackson II”), and cert. granted, 143 S. Ct. 2457 (2023) (Ground Four). (See Doc. 5). This Court granted Stephens’s motion and

directed him to file an amended Section 2255 motion. (Doc. 10). Stephens failed to do so. Nonetheless, in an abundance of caution, this Court will only address the claims raised in Stephens’s initial 28 U.S.C. § 2255 motion (Doc. 1) and his motion to amend (Doc. 5). For the reasons argued by the United States, Stephens’s claims are each untimely, procedurally defaulted, or without merit. III. SECTION 2255 MOTION

A. Timeliness Section 2255(f) requires a claim-by-claim assessment to determine timeliness. See Beeman v. United States, 871 F.3d 1215, 1219 (11th Cir. 2017). Section 2255(f)(3) provides a one-year limitations period that begins on “the date on which the right

asserted was initially recognized by the Court, if that right has been newly recognized by the Court and made retroactively applicable to cases on collateral review.” Section 2255(f)(3)’s “‘new right’ trigger applies to Supreme Court decisions recognizing new, retroactively applicable statutory rights.” Zack v. Tucker, 704 F.3d 917, 925 (11th Cir. 2013) (en banc) (citing United States v. Roberts, 308 F.3d 1147, 1149–50 (11th Cir. 2002).

Any court, including a district court, can decide whether that right is retroactive. See Dodd v. United States, 365 F.3d 1273, 1280–81 (11th Cir. 2004), aff’d on other grounds, 545 U.S. 353 (2005).

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