Mpetshi v. United States

CourtDistrict Court, C.D. Illinois
DecidedApril 5, 2022
Docket3:22-cv-03037
StatusUnknown

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

Bluebook
Mpetshi v. United States, (C.D. Ill. 2022).

Opinion

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF ILLINOIS SPRINGFIELD DIVISION

WEST KINIOKI MPETSHI, ) ) Petitioner-Defendant, ) ) v. ) Case No. 17-cr-30074 ) 22-cv-3037 ) UNITED STATES OF AMERICA, ) ) Respondent-Plaintiff. )

ORDER AND OPINION

SUE E. MYERSCOUGH, U.S. District Judge: Before the Court is Petitioner West Kinoioki Mpetshi’s Motion to Vacate, Set Aside, or Correct Sentence pursuant to 28 U.S.C. § 2255 (d/e 133). Mr. Mpetshi argues that he should not have received a two-level enhancement in his sentencing guidelines calculations. The Court has reviewed the Motion pursuant to 28 U.S.C. §§ 2243, 2255, and Rule 4 of the Rules Governing Section 2255 Proceedings for the United States District Courts. As explained below, the Court finds that the Petitioner’s Motion (d/e 133) must be SUMMARILY DISMISSED. The Court DECLINES to issue a certificate of appealability. I. BACKGROUND In August 2019, a jury found Mr. Mpetshi guilty of two counts

of filing false income tax returns, in violation of 26 U.S.C. § 7206(1), and 28 counts of aiding and assisting in the preparation and presentation of false income tax returns, in violation of 26 U.S.C.

§ 7206(2). See Jury Verdict (d/e 68). The United States Probation Office prepared a Presentence Investigation Report in advance of sentencing. See PSR (d/e 110).

The PSR determined that the base offense level under the advisory sentencing guidelines was 18 and that a two-level enhancement applied for abuse of a position of trust by use of a special skill

under U.S.S.G. § 3B1.3. PSR ¶¶26, 29. Accordingly, Mr. Mpetshi’s total offense level became 20. PSR ¶34. Combined with Mr. Mpetshi’s criminal history category of I, his advisory sentencing

guidelines range was 33 to 41 months’ imprisonment. At the sentencing hearing on July 16, 2021, Mr. Mpetshi raised three objections to the PSR, including to the two-level enhancement. However, the Court overruled the objections. See

Transcript (d/e 126) at 9-10. The Court sentenced Mr. Mpetshi to a total term of 33 months’ imprisonment and one year of supervised release. See Judgment (d/e 116).

Mr. Mpetshi then filed a timely appeal to the Seventh Circuit. See United States v. Mpetshi, 21-2392 (7th Cir.). After receiving a letter from his attorney that an Anders brief was forthcoming,

Defendant dismissed his appeal. See Mandate (d/e 129); Motion to Withdraw (d/e 132). On March 10, 2022, Mr. Mpetshi filed this Motion to Vacate,

Set Aside, or Correct Sentence pursuant to 28 U.S.C. § 2255. He alleges that the Court should not have increased his guideline range by two-levels under U.S.S.G. § 3B1.3. See Motion (d/e 133) at 4,

13-15. Prior to the Court conducting its review under Rule 4 of the Rules Governing Section 2255 Proceedings for the United States District Courts, the Government filed a response (d/e 136). The

Government argues that Mr. Mpetshi’s claim is procedurally defaulted, not cognizable on collateral review, and meritless. This Order now follows. II. DISCUSSION

Under to Rule 4 of the Rules Governing Section 2255 Proceedings for the United States District Courts, the Court must dismiss the motion “[i]f it plainly appears from the motion, any attached exhibits, and the record of prior proceedings that the

moving party is not entitled to relief.” While the Government has already filed a response, the Court concludes that the motion is also subject to summary dismissal because the claimed error is not

cognizable in collateral review. As the Government has noted, the Seventh Circuit has repeatedly found that non-constitutional claims of errors in the

calculation of a defendant’s advisory sentencing guidelines cannot be raised on collateral review so long as the sentence actually imposed was not greater than the statutory maximum. See

Hawkins v. United States, 706 F.3d 820, 824 (7th Cir.), opinion supplemented on denial of reh’g, 724 F.3d 915 (7th Cir. 2013); United States v. Coleman, 763 F.3d 706, 708 (7th Cir. 2014), as

amended on denial of reh’g and reh’g en banc (Oct. 16, 2014); Hanson v. United States, 941 F.3d 874, 876 (7th Cir. 2019). As the Seventh Circuit explained in Hawkins, after the sentencing guidelines became advisory, a “judge may not even presume that a

sentence within the applicable guidelines range would be proper. He must determine whether it is consistent with the sentencing considerations set forth in 18 U.S.C. § 3553(a), and if he finds it is not he may not impose it even though it is within the applicable

guidelines range.” Hawkins, 706 F.3d at 822. Even had the judge not made the alleged error in calculating the guidelines range, the judge still would not be required to give a lower a sentence. Id. at

824. Accordingly, the Seventh Circuit found that “a sentence that is well below the ceiling imposed by Congress . . . [cannot] be considered a ‘miscarriage of justice’ that can be collaterally

attacked, just because the judge committed a mistake en route to imposing it.” Id. at 824-25. The Seventh Circuit acknowledged that the error might not be harmless, “but not every error is corrigible in

a postconviction proceeding, even if the error is not harmless.” Id. at 823. Here, Mr. Mpetshi’s sentence of 33 months’ imprisonment is

below the statutory maximum of three years per count. See 26 U.S.C. §§ 7206(1), 7206(2). The purported error in applying a two- level increase in Mr. Mpetshi’s offense level is not cognizable in a § 2255 motion. III. CERTIFICATE OF APPEALABILITY If Petitioner seeks to appeal this decision, he must first obtain

a certificate of appealability. See 28 U.S.C. § 2253(c) (providing that an appeal may not be taken to the court of appeals from the final order in a § 2255 proceeding unless a circuit justice or judge issues

a certificate of appealability). A certificate of appealability may issue only if Petitioner has made a “substantial showing of the denial of a constitutional right.” 28 U.S.C. § 2253(c)(2). Such a

showing is made if “reasonable jurists could debate whether (or, for that matter, agree that) the petition should have been resolved in a different manner.” Slack v. McDaniel, 529 U.S. 473, 484, 120

S. Ct. 1595 (2000). When a federal habeas petition is dismissed on procedural grounds without reaching the underlying constitutional claim, the movant must show “that jurists of reason would find it

debatable whether the petition states a valid claim of the denial of a constitutional right and that jurists of reason would find it debatable whether the district court was correct in its procedural ruling.” Id.

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