Prince v. United States

CourtDistrict Court, N.D. Alabama
DecidedMay 1, 2023
Docket7:20-cv-08031
StatusUnknown

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

Bluebook
Prince v. United States, (N.D. Ala. 2023).

Opinion

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ALABAMA WESTERN DIVISION

Reginald Prince, )

) Petitioner, ) 7:20-cv-08031-LSC v. ) 7:18-cr-00399-LSC

) United States of America, ) Respondent. )

MEMORANDU M OF OPINION Pursuant to 28 U.S.C. § 2255 (“§ 2255”), Reginald Prince (“Prince”) filed with the Clerk of this Court a motion to vacate, set aside, or otherwise correct his sentence. (Doc. 1.) The United States responded in opposition to the motion. (Doc. 3.) For the following reasons, Prince’s § 2255 motion is due to be dismissed. I. BACKGROUND In August 2018, a grand jury indicted Prince on the following four counts: Count I—distribution and possession with intent to distribute crack cocaine in violation of 21 U.S.C. § 841(a)(1) and (b)(1)(C); Count II—distribution and possession with intent to distribute marijuana in violation of 21 U.S.C. § 841(a)(1) and (b)(1)(D); Count III—possession of a firearm in furtherance of a drug trafficking crime in violation of 18

U.S.C. § 924(c)(1)(A); Count IV—possession of a firearm after having been convicted of qualifying felony offenses in violation of 18 U.S.C. § 922(g)(1). (Cr. Doc 1.)

In December 2018, Prince entered into, and this Court accepted, a guilty plea as to Counts I, III, and IV. (Cr. Doc. 15.) The government agreed to dismiss Count II. (Id.) In April 2019, the Court sentenced

Prince to 120 months of imprisonment with a term of supervised release to follow. (Cr. Doc. 21.) The Court accepts Prince’s claim that he mailed his § 2255 motion

on April 10, 2020 (doc. 1 at 17), which entails that the motion is timely. See 28 U.S.C. § 2255(f)(1). By all accounts, Prince has not filed a prior § 2255 motion, so it is not “second or successive” within the meaning of the

Anti-Terrorism and Effective Death Penalty Act of 1996 (“AEDPA”). See 28 U.S.C. §§ 2255(h), 2244(b)(3)(A). Because Prince is a pro se litigant, the Court liberally construes his pleadings. See Tannenbaum v. United

States, 148 F.3d 1262, 1263 (11th Cir. 1998) (per curiam). II. STANDARD OF REVIEW Because collateral review is not a substitute for direct appeal, the grounds for collateral attack on final judgments pursuant to 28 U.S.C. §

2255 are limited. A petitioner is entitled to relief under § 2255 if the court imposed a sentence that (1) violated the Constitution or laws of the United States, (2) exceeded its jurisdiction, (3) exceeded the maximum

authorized by law, or (4) is otherwise subject to collateral attack. See 28 U.S.C. § 2255; United States v. Phillips, 225 F.3d 1198, 1199 (11th Cir. 2000); United States v. Walker, 198 F.3d 811, 813 n.5 (11th Cir. 1999).

“Relief under 28 U.S.C. § 2255 ‘is reserved for transgressions of constitutional rights and for that narrow compass of other injury that could not have been raised in direct appeal and would, if condoned, result

in a complete miscarriage of justice.’” Lynn v. United States, 365 F.3d 1225, 1232 (11th Cir. 2004) (quoting Richards v. United States, 837 F.2d 965, 966 (11th Cir. 1988)).

In litigation stemming from a § 2255 motion, “[a] hearing is not required on patently frivolous claims or those which are based upon unsupported generalizations. Nor is a hearing required where the

[movant’s] allegations are affirmatively contradicted by the record.” Holmes v. United States, 876 F.2d 1545, 1553 (11th Cir. 1989) (quoting Guerra v. United States, 588 F.2d 519, 520–21 (5th Cir. 1979)). However, an evidentiary hearing is appropriate if, “accept[ing] all of the petitioner’s

alleged facts as true,” the movant has “allege[d] facts which, if proven, would entitle him to relief.” Diaz v. United States, 930 F.2d 832, 834 (11th Cir. 1991) (quoting Agan v. Dugger, 835 F.2d 1337, 1338 (11th Cir. 1987)

and Futch v. Dugger, 874 F.2d 1483, 1485 (11th Cir. 1989)). III. DISCUSSION In his § 2255 motion, Prince claims that his attorney violated his

right to effective assistance of counsel in three ways. First, Prince argues that his attorney should have objected to the 18 U.S.C. § 922(g)(1) charge because Prince was not previously convicted of a violent felony. Second,

Prince argues that his attorney should have objected to the 18 U.S.C. § 924(c) charge because 21 U.S.C. § 841(a)(1) does not qualify as a drug trafficking crime. Third, Prince argues that his attorney should have

objected to the term “excessive use of alcohol” in the Court’s standard conditions of supervised release as this phrase is too vague. Each of these arguments is without merit.

Claims of ineffective assistance of counsel may be raised for the first time in a § 2255 motion and are therefore not subject to a procedural bar for failing to raise them on direct appeal. See Massaro v. United States, 538 U.S. 500, 504 (2003). An ineffective assistance of counsel claim has

two components: first, the petitioner “must show that the counsel’s performance was deficient;” second, the petitioner “must show that the deficient performance prejudiced the defense.” Strickland v. Washington,

466 U.S. 668, 687 (1984). To satisfy the first component, the petitioner “must show that counsel’s representation fell below an objective standard of reasonableness.” Id. at 688. The second component is satisfied only

when the defendant shows that “there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different.” Id. at 694.

In examining counsel’s performance, the Court should be “highly deferential.” Id. at 689. The Court must make “every effort . . . to eliminate the distorting effects of hindsight, to reconstruct the

circumstances of counsel’s challenged conduct, and to evaluate the conduct from counsel’s perspective at the time.” Id.

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