Patrick Chasse v. United States of America

2016 DNH 164
CourtDistrict Court, D. New Hampshire
DecidedSeptember 15, 2016
Docket15-cv-473-PB
StatusPublished

This text of 2016 DNH 164 (Patrick Chasse v. United States of America) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Patrick Chasse v. United States of America, 2016 DNH 164 (D.N.H. 2016).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Patrick Chasse

v. Civil No. 15-cv-473-PB Opinion No. 2016 DNH 164 United States of America

AMENDED MEMORANDUM AND ORDER

18 U.S.C. § 924(c) punishes those who use a firearm during

and in relation to “any crime of violence.” As used in §

924(c), “crime of violence” means a felony offense that either

“has as an element the use, attempted use, or threatened use of

physical force against the person or property of another,” (the

“force clause”), or “by its nature, involves a substantial risk

that physical force against the person or property of another

may be used in the course of committing the offense,” (the

“residual clause”). 18 U.S.C. § 924(c)(3). In Johnson v.

United States, 135 S. Ct. 2551 (2015), the United States Supreme

Court held that the residual clause in 18 U.S.C. §

924(e)(2)(B)’s definition of “violent felony,” which is similar

to the residual clause in § 924(c), is unconstitutionally vague.

The Court later made its holding in Johnson retroactive in Welch

v. United States, 136 S. Ct. 1257 (2016). Patrick Chasse, the petitioner here, pleaded guilty to

several offenses in 2011, including two counts of “us[ing],

carr[ying], and brandish[ing]” a firearm “during and in relation

to a crime of violence,” in violation of 18 U.S.C. § 924(c).

The underlying “crime[s] of violence” for those § 924(c)

convictions were federal bank robbery and pharmacy robbery.1

Chasse has since filed a 28 U.S.C. § 2255 motion to vacate his §

924(c) convictions, arguing that Johnson requires a conclusion

that § 924(c)’s residual clause is unconstitutionally vague, and

that federal bank robbery and pharmacy robbery are not crimes of

violence under § 924(c)’s force clause.

The government opposes Chasse’s motion. It argues that

Chasse procedurally defaulted on this claim by failing to raise

it previously, and that he cannot show the cause and actual

prejudice needed to excuse his default. In particular, the

government contends that Chasse cannot establish prejudice,

because federal bank robbery and pharmacy robbery are both

crimes of violence under § 924(c)’s force clause. Therefore,

according to the government, even assuming that Johnson renders

§ 924(c)’s residual clause unconstitutional, Chasse is not

1 In one of its briefs, the government incorrectly suggested that Chasse’s predicate “crime of violence” was Hobbs Act robbery, 18 U.S.C. § 1951. See Doc. No. 18 at 26-27. 2 entitled to § 2255 relief.2

I. BACKGROUND

During the fall of 2010, Patrick Chasse and two co-

conspirators committed a series of armed robberies. Following

those crimes, in June 2011, a grand jury returned a twenty-

eight-count superseding indictment against Chasse and his

associates. See Superseding Indictment, United States v.

Chasse, No. 11-cr-52-PB (D.N.H. June 8, 2011), Doc. No. 32. The

indictment included two 18 U.S.C. § 924(c) charges against

Chasse, Counts Five and Twenty.3 See Presentence Investigation

Report at 1-2, United States v. Chasse, No. 11-cr-52-PB (D.N.H.

May 10, 2012), Doc. No. 84 (Sealed).

2 Chasse’s pro se § 2255 petition includes additional challenges to his convictions, including an ineffective assistance of counsel claim. See Doc. Nos. 8 at 5; 15. I will address those issues in a separate Memorandum and Order.

3 The superseding indictment included four § 924(c) charges against Chasse -- Counts Five, Nine, Sixteen, and Twenty. See Superseding Indictment, United States v. Chasse, No. 11-cr-52-PB (D.N.H. June 8, 2011), Doc. No. 32. Counts Nine and Sixteen were dismissed pursuant to Chasse’s plea agreement, however, and Chasse was convicted of only the § 924(c) charges set out in Counts Five and Twenty. See Judgment, United States v. Chasse, No. 11-cr-52-PB (D.N.H. May 25, 2012), Doc. No. 91. I address only those counts here.

3 The § 924(c) counts stemmed from two incidents. Count Five

resulted from a September 2010 robbery at a TD Bank branch in

Manchester, New Hampshire. Superseding Indictment at 5, United

States v. Chasse, No. 11-cr-52-PB (D.N.H. June 8, 2011), Doc.

No. 32. The underlying “crime of violence” for Count Five was

federal bank robbery, 18 U.S.C. § 2113(a) and (d) (Count Three).

Id. at 3. Count Twenty was based on a November 2010 robbery at

a Rite Aid Pharmacy in Manchester. Id. at 20. The underlying

“crime of violence” for Count Twenty was pharmacy robbery, 18

U.S.C. § 2118(a) and (c)(1) (Count Eighteen). Id. at 18.

In September 2011, Chasse pleaded guilty to a number of the

charges against him, including the two § 924(c) counts, and the

underlying federal bank robbery and pharmacy robbery charges.

He was later sentenced to a total term of imprisonment of 239

months and one day -- a 120 month sentence on Count Five, a 119

month sentence on Count Twenty, and a one day sentence on all

other counts. Judgment at 3, United States v. Chasse, No. 11-

cr-52-PB (D.N.H. May 25, 2012), Doc. No. 91. The sentences on

Counts Five and Twenty were ordered to be served consecutively

to each other and to the other counts, pursuant to §

924(c)(1)(A).

4 II. ANALYSIS

Chasse seeks to vacate his § 924(c) convictions, claiming

that § 924(c)’s residual clause is unconstitutionally vague in

light of Johnson v. United States, 135 S. Ct. 2551 (2015), and

that federal bank robbery and pharmacy robbery do not qualify as

“crimes of violence” under § 924(c)’s force clause. The

government responds that Chasse procedurally defaulted on this

claim by failing to raise it previously, and that he cannot

demonstrate the cause and prejudice required to excuse that

default. To put these arguments into context, I begin by

describing Johnson and § 924(c), then outline the procedural

default rule, and finally turn to the government’s assertion

that federal bank robbery and pharmacy robbery constitute

“crimes of violence” under § 924(c)’s force clause.

A. Johnson and § 924(c)

In Johnson, the Supreme Court addressed the definition of

“violent felony” under the Armed Career Criminal Act (“ACCA”),

18 U.S.C. § 924(e)(2). Federal law prohibits a felon from

possessing a firearm. 18 U.S.C. § 922(g); Welch, 136 S. Ct. at

1261. Pursuant to the ACCA, a felon who possesses a firearm

after three or more convictions for a “violent felony” faces an

enhanced sentence. 18 U.S.C. § 924(e)(1).

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