Pilcher v. United States

CourtDistrict Court, D. Vermont
DecidedDecember 14, 2020
Docket5:18-cv-00084
StatusUnknown

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

Bluebook
Pilcher v. United States, (D. Vt. 2020).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF VERMONT AUDEC 14 AM □□□ | UNITED STATES OF AMERICA ) bw Vv. Case No. 5:14-cr-58 ee CLERK JOHN PILCHER, Defendant. ORDER (Docs. 104, 118, 126, 131, 132) The Magistrate Judge issued a Report and Recommendation (R&R) on May 11, 2020. (Doc. 131.) Defendant Pilcher, who represents himself, has filed an Objection to the R&R. (Doc. 134.) After review of the file and the Magistrate Judge’s thorough Report and Recommendation, the Report and Recommendation is AFFIRMED, APPROVED and ADOPTED. See 28 U.S.C. § 636(b)(1). Analysis A district judge must make a de novo determination of those portions of a magistrate judge’s report and recommendation to which an objection is made. Fed. R. Civ. P. 72(b)(3); 28 U.S.C. § 636(b)(1); Cullen v. United States, 194 F.3d 401, 405 (2d Cir. 1999). The district judge may “accept, reject, or modify, in whole or in part, the findings or recommendations made by the magistrate judge.” 28 U.S.C. § 636(b)(1); accord Cullen, 194 F.3d at 405. I. Background As noted in the R&R, Pilcher has filed a motion pursuant to 28 U.S.C. § 2255 to vacate, correct, or set aside the sentence imposed in 2016 as a result of his plea of guilty to one count of knowingly possessing child pornography in violation of 18 U.S.C. § 2252(a)(4). (Doc. 104.) Pilcher has served the 8-month prison term of his sentence and seeks relief from the terms of

supervised release to which he agreed in the plea agreement. (Doc. 68.) The focus of Pilcher’s § 2255 Motion and his Objection to the R&R is a legal argument regarding the applicability of Packingham v. North Carolina, 137 S. Ct. 1730 (2017), to Pilcher’s sentence. In Packingham, the Supreme Court ruled that a North Carolina statute making it a felony for a registered sex offender “to access a commercial social networking Web site where the sex offender knows that the site permits minor children to become members or to create or maintain Web pages” violated the First Amendment. See N.C. Gen. Stat. Ann §§ 14-202.5(a), (e) (2015). The Court held that “to foreclose access to social media altogether is to prevent the user from engaging in the legitimate exercise of First Amendment rights.” Packingham, 137 S. Ct. at 1737. Pilcher seeks to extend the First Amendment principle recognized in Packingham to his own conditions of supervised release. He seeks to challenge “the infringement of my rights beyond what the Supreme Court has since deemed constitutional.” (Doc. 104 at 4.) He specifically identifies conditions “prohibit[ing him] from participating in Facebook/Twitter and any social media websites.” (/d. at 5.) He identifies a politically oriented blog which provided him with an outlet “to discuss politics and news events” as well as personal and business use of Facebook and Twitter. Pilcher contends that the terms of his supervised release are inconsistent with the Supreme Court’s decision in Packingham, and that, had Packingham been decided prior to Pilcher’s acceptance of the plea deal, he would not have agreed to the conditions of supervised release that now bind him. (Doc. 104 at 6.) In response, the Government argues that Pilcher’s § 2255 motion is barred by the statute of limitations and that Pilcher’s reliance on Packingham does not implicate the exception set forth in 28 U.S.C. § 2255(f)(3) and described in Teague v. Lane, 489 U.S. 288 (1989). (Doc. 118 at 2.) The Government also argues that Pilcher’s request is

more accurately characterized as a motion to modify the conditions of release under 18 U.S.C. § 3583(e), and that the Packingham decision does not authorize such a modification. (Doc. 118 at 5-6.) The R&R concludes that Pilcher’s appeal is barred by the one-year statute of limitations set by 28 U.S.C. § 2255 (Doc. 131 at 6-7) and by the rule of procedural default (Doc. 131 at 8— 9). The R&R also concludes that, even in the absence of these procedural bars, the Packingham ruling does not apply to conditions of supervised release. (Doc. 131 at 10-12.) Pilcher objects to the R&R’s decision regarding the application of Packingham to his claim and argues that the retroactive application of Packingham enables his § 2255 Motion to overcome the procedural bars. (Doc. 134.) Il. Relevance of Packingham A. Packingham and the § 2255 Statute of Limitations Section 2255 imposes a one-year statute of limitations on motions to vacate, set aside, or correct a sentence. 28 U.S.C. § 2255(f). The limitations period runs from the date of conviction unless one of three exceptions applies. Jd. In his Objection, Pilcher renews the argument in his original § 2255 motion that the Supreme Court’s decision in Packingham brings his challenge within the exception created by § 2255(f)(3) (Doc. 134 at 3), which grants a one-year period to file starting on “the date on which the right asserted was initially recognized by the Supreme Court and made retroactively applicable to cases on collateral review.” 28 U.S.C. § 225(f)(3). Specifically, Pilcher objects to the Magistrate Judge’s conclusion that “the Court in Packingham did not make any newly recognized right retroactive to cases on collateral review.” (Doc. 131 at 7) He writes: The Supreme Court would not waste its time to review a case if it did not have some broad message to send and want its opinion to be interpreted at least

somewhat more broadly than the specifics of a given case. .. . [O|]ne must assume that when it takes so long for the Court to speak out on such critically important topics as the these that it does so with great intent to speak to a broad issue with profound importance. (Doc. 134 at 13.) Alternatively, Pilcher objects to the Magistrate Judge’s determination that he is not entitled to equitable tolling. (See, e.g., id. at 18.) Upon review, the court agrees with the Magistrate Judge that neither of these exceptions operates to extend the limitation period beyond the one year following final judgment. Section 2255(f)(3) anticipates that in appropriate cases, the federal courts may apply a Supreme Court decision retroactively despite the expiration of the one-year statute of limitations. In such cases, the one-year limitations period runs from “the date on which the right asserted was initially recognized by the Supreme Court, if that right has been newly recognized by the Supreme Court and made retroactively applicable to cases on collateral review.” 28 U.S.C. § 2255(f)(3). The statute requires two events: a right newly recognized by the Supreme Court and a judicial ruling that the right applies retroactively. See Dodd v.

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Related

Teague v. Lane
489 U.S. 288 (Supreme Court, 1989)
Bernard Cullen v. United States
194 F.3d 401 (Second Circuit, 1999)
Billy Ray Ashley v. United States
266 F.3d 671 (Seventh Circuit, 2001)
Dodd v. United States
545 U.S. 353 (Supreme Court, 2005)
Packingham v. North Carolina
582 U.S. 98 (Supreme Court, 2017)
United States v. Olvera
775 F.3d 726 (Fifth Circuit, 2015)
United States v. Eaglin
913 F.3d 88 (Second Circuit, 2019)

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Bluebook (online)
Pilcher v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pilcher-v-united-states-vtd-2020.