Mitchell v. United States

CourtDistrict Court, M.D. Florida
DecidedMarch 10, 2025
Docket8:24-cv-00873
StatusUnknown

This text of Mitchell v. United States (Mitchell v. United States) 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
Mitchell v. United States, (M.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION

MARVIN MITCHELL, Petitioner, v. Case No. 8:24-cv-873-TPB-TGW Case No. 8:19-cr-529-TPB-TGW UNITED STATES OF AMERICA, Respondent. ____________________________________

ORDER DENYING MOTION TO VACATE SENTENCE Marvin Mitchell moves under 28 U.S.C. § 2255 to vacate his convictions and sentence for conspiracy to distribute and distributing controlled substances. After pleading guilty, he is currently serving a sentence of 180 months. In this action, he challenges his convictions and sentence on six grounds and claims he received constitutionally ineffective assistance of counsel. Mitchell is entitled to no relief. I. Background Mitchell was charged with conspiring to distribute, and possess with the intent to distribute, cocaine base, fentanyl, and heroine resulting in a death, in violation of 21 U.S.C. §§ 846 and 841(b)(2)(C) (Count One); distributing, and possessing with the intent to distribute, fentanyl resulting in a death, in violation of 21 U.S.C. §§ 841(a)(1) and 841(b)(1)(C) and 18 U.S.C. § 2 (Count Two); distributing, and possessing with the intent to distribute, fentanyl and heroin, in violation of 21 U.S.C. § 841(a)(1) and 18 U.S.C. § 2 (Count Three); and possessing with the intent to distribute cocaine base, fentanyl, and heroin, in violation of 21 U.S.C. §§ 841(a)(1) 841(b)(1)(C) and 18 U.S.C. § 2 (Count

Four). (Crim. Doc. 61) Under a plea agreement, Mitchell pleaded guilty to lesser included offenses charged in Counts One and Two, absent the allegations that the offenses resulted in a death. (Crim. Doc. 144 at 1–2) Specifically, he pleaded guilty to conspiracy to distribute, and possess with intent to distribute,

cocaine base, fentanyl, and heroin (Count One) and possession with intent to distribute fentanyl and heroine (Count Two). (Id.) The United States agreed to dismiss the remaining counts and to make specific sentencing recommendations. (Id. at 3–4)

At sentencing, the United States objected to the U.S. Probation Office’s conclusion that Mitchell did not qualify as a career offender under U.S. Sentencing Guidelines § 4B1.1. (Crim. Doc. 158 at ¶ 63) The Court sustained the objection and found Mitchell to be a career offender. (Crim. Doc. 172 at 32

and 42) One of Mitchell’s offenses of conviction (Count Two) was a controlled substance offense, and he had two prior felony controlled substance offenses, including a 2008 Florida conviction for possession of cocaine with the intent to sell, manufacture, or deliver, and a 2009 Florida conviction for sale and

delivery of cocaine. (Crim. Doc. 165 at ¶ 63, final presentence report with Court corrections) Mitchell objected to the drug weight attributed to him in the presentence report. To overcome that objection, the United States called one of Mitchell’s

co-conspirators, Emma Leifer. Based on her testimony, the Court overruled Mitchell’s objection and held him accountable for 286.8 grams of fentanyl, 1.2 grams of fentanyl analogue, and 5.63 grams of cocaine base, which amounted to a total converted drug weight of 749.10 kilograms. (Crim. Doc. 172 at 25;

Crim. Doc. 165 at ¶ 57) Under U.S.S.G. § 2D1.1(a)(5) and (c)(6), Mitchell’s base offense level was 28 because his offenses involved between 700 and 1,000 kilograms of total converted drug weight. (Crim. Doc. 165 at ¶ 57) With a total offense level of 29 and a criminal history category of VI, the

Probation Office calculated an advisory guidelines range of 151 to 188 months. (Crim. Doc. 165 at ¶ 148) The Court sentenced Mitchell to 180 months, and a judgment was entered against him on August 22, 2022. (Crim. Doc. 166) On direct appeal, Mitchell argued that the Court erred by sentencing

him as a career offender and in determining the amount of drugs attributed to him. United States v. Mitchell, No. 22-12889, 2023 WL 565544 (11th Cir. Jan. 23, 2023) (brief of appellant). The Eleventh Circuit dismissed the appeal based on the sentence-appeal waiver in his plea agreement. United States v. Mitchell,

No. 22-12889, 2023 WL 3085332, at *1 (11th Cir. Apr. 26, 2023). II. Analysis Mitchell now moves to vacate his convictions and sentence and claims:

(1) he is not a career offender after United States v. Dupree, 57 F.4th 1269 (11th Cir. 2023) (en banc), and both trial and appellate counsel were ineffective for not challenging his career offender designation based on Dupree; (2) his Florida convictions are not predicate controlled substance offenses, and trial counsel

was ineffective for not challenging his career offender designation on this basis; (3) appellate counsel was ineffective for not requesting that his appeal be stayed pending the resolution of United States v. Jackson, 55 F.4th 846 (11th Cir. 2022); (4) the plea agreement is vague because he did not know he could

be sentenced as a career offender, and trial counsel was ineffective for allowing him to plead guilty to a vague plea agreement; (5) the plea agreement is defective because it does not specify the length of supervised release he faced, and trial counsel was ineffective for allowing him to plead guilty to an

indeterminate amount of supervised release; and (6) the Court erred in determining the amount of drugs attributed to him, and counsel was ineffective for not challenging the Court’s determination. The United States responds that Mitchell’s claims are procedurally defaulted and meritless.1 Mitchell’s

1 The Court rejects Mitchell’s claims as meritless. See Dallas v. Warden, 964 F.3d 1285, 1307 (11th Cir. 2020) (“[A] federal court may skip over the procedural default analysis if a claim would fail on the merits in any event.”); Garrison v. United States, 73 F.4th 1354, 1359 n.9 (11th Cir. 2023) (same). claims lack merit, and this motion must be denied. 2 To prevail on a claim of ineffective assistance of counsel, the petitioner

must show that (1) counsel’s representation fell below an objective standard of reasonable professional assistance; and (2) the petitioner was prejudiced by that deficient performance. Strickland v. Washington, 466 U.S. 668, 693–94 (1984). To establish deficient performance, a petitioner must show that “no

competent counsel would have taken the action that his counsel did take.” Chandler v. United States, 218 F.3d 1305, 1315 (11th Cir. 2000) (en banc). A petitioner demonstrates prejudice only when he establishes “a reasonable probability that, but for counsel’s unprofessional errors, the result of the

proceeding would have been different.” Strickland, 466 U.S. at 694. A. Ground One Mitchell claims that he is not a career offender after Dupree and that both trial and appellate counsel were ineffective for not challenging his career

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