Richard M. Smith v. United States of America

CourtDistrict Court, M.D. Alabama
DecidedJanuary 28, 2026
Docket2:23-cv-00745
StatusUnknown

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

Bluebook
Richard M. Smith v. United States of America, (M.D. Ala. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA NORTHERN DIVISION

RICHARD M. SMITH ) ) ) ) v. ) CASE NO. 2:23-CV-00745-RAH ) UNITED STATES OF AMERICA ) ) MEMORANDUM OPINION AND ORDER Pending before the Court is Richard M. Smith’s Motion to Vacate under 28 U.S.C. § 2255 which collaterally attacks his sentence in United States v. Smith, No. 2:19-cr-00122-RAH-JTA (M.D. Ala. Feb. 3, 2022). The Motion will be denied. BACKGROUND On March 12, 2019, Smith was indicted on four counts—conspiracy to distribute and possess with the intent to distribute a controlled substance (cocaine powder), possession with the intent to distribute a controlled substance (cocaine powder), possession of a firearm during and in relation to a drug-trafficking crime, and a money-laundering conspiracy. Smith’s wife was also charged in the conspiracy. A superseding indictment added a co-defendant (Ronnie White) and an additional charge against Smith for the use of a communication facility to further the conspiracy. Smith and his wife proceeded to trial in June 2021. The other co-defendant pled guilty and testified against Smith. The jury returned a guilty verdict against Smith on four counts, and a not guilty verdict on the money laundering conspiracy count. During his initial sentencing on December 7, 2021, Smith submitted a handwritten motion to dismiss the indictment and discharged his retained counsel, Preston Presley and Wesley Pitters, for claimed performance issues. The sentencing was thus continued to a later date so that Smith could obtain new counsel and review the presentence report. Smith retained new counsel and his sentencing proceeded on February 2, 2022. He received a total sentence of 145 months, which included an 85-month sentence on the conspiracy and drug counts plus an additional 60 months on the firearm count. Smith appealed to the Eleventh Circuit, focusing only on his pre-trial suppression motion which had been denied. Smith did not raise any claimed error during the trial or sentencing. On December 27, 2022, the Eleventh Circuit affirmed this Court’s denial of Smith’s suppression motion, finding that “the officer had sufficient evidence supporting a reasonable suspicion that Smith was transporting drugs to a dealer in the area, warranting the extension of the traffic stop and detention of Smith.” United States v. Smith, No. 22-10489, 2022 WL 17958923, at *1 (11th Cir. Dec. 27, 2022) (per curiam). Smith’s conviction was therefore affirmed. On December 27, 2023, Smith filed the instant Motion to Vacate pursuant to 28 U.S.C. § 2255, in which he asserts six instances of alleged ineffective assistance of counsel (1) “by failing to file a Motion in Limine or object to an unlawful wiretap extension authorization, which included phone calls from Petitioner”; (2) “failing to object to prejudicial testimony that was introduced at trial” from two witnesses— Patricia Hill and Karl Oroz; (3) “by failing to adequately investigate”; (4) “by failing to object to jurors with memory issues and sleeping during trial”; (5) “by failing to adequately consult with Petitioner regarding his trial and sentencing”; and (6) by failing “to argue any of the issues presented in this Petition related to Petitioner’s trial and sentencing.” The Government argues that Smith’s ineffectiveness claims are without merit. LEGAL STANDARD Under § 2255, “[a] prisoner in custody under sentence of a court established by Act of Congress claiming the right to be released upon the ground that the sentence was imposed in violation of the Constitution . . . may move the court which imposed the sentence to vacate, set aside, or correct the sentence.” 28 U.S.C. § 2255(a). Because collateral review is not a substitute for direct appeal, the grounds for collateral attack on final judgments under § 2255 are extremely limited. See United States v. Frady, 456 U.S. 152, 165 (1982). A prisoner 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. 28 U.S.C. § 2255(a); McKay v. United States, 657 F.3d 1190, 1194 n.8 (11th Cir. 2011). “[R]elief 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) (per curiam) (cleaned up). The law is well established that a district court need not reconsider issues raised in a § 2255 motion which have been resolved on direct appeal. Stoufflet v. United States, 757 F.3d 1236, 1239 (11th Cir. 2014); Rozier v. United States, 701 F.3d 681, 684 (11th Cir. 2012). Once a matter has been decided adversely to a defendant on direct appeal, it cannot be re-litigated in a collateral attack under § 2255. United States v. Nyhuis, 211 F.3d 1340, 1343 (11th Cir. 2000). Broad discretion is afforded to a court’s determination of whether a particular claim has been previously raised. See Sanders v. United States, 373 U.S. 1, 16 (1963) (“[I]dentical grounds may often be proved by different factual allegations . . . [or] supported by different legal arguments . . . or be couched in different language . . . or vary in immaterial respects.” (citations omitted)). Because a motion to vacate under § 2255 is not a substitute for direct appeal, issues which could have been raised on direct appeal are generally not actionable in a § 2255 motion and will be considered procedurally barred. Lynn, 365 F.3d at 1234; McKay, 657 F.3d at1195. An issue is “‘available’ on direct appeal when its merits can be reviewed without further factual development.” Lynn, 365 F.3d at 1232 n.14 (quoting Mills v. United States, 36 F.3d 1052, 1055 (11th Cir. 1994)). Absent a showing that the ground of error was unavailable on direct appeal, a court may not consider the ground in a § 2255 motion unless the defendant establishes one of two exceptions. As to the first, the defendant must show (1) cause for not raising the ground on direct appeal and (2) actual prejudice resulting from the alleged error. Id. at 1234. Alternatively, a court may consider the ground if the defendant shows that he is “actually innocent.” Id. To show cause for procedural default, a defendant must show that “some objective factor external to the defense prevented [him] or his counsel from raising his claims on direct appeal and that this factor cannot be fairly attributable to [the defendant’s] own conduct.” Id. at 1235. A meritorious claim of ineffective assistance of counsel can constitute cause. See Nyhuis, 211 F.3d at 1344. Ineffective assistance of counsel claims are generally not cognizable on direct appeal and are properly raised by a § 2255 motion regardless of whether they could have been brought on direct appeal. Massaro v. United States, 538 U.S. 500, 503 (2003); see also United States v.

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Bluebook (online)
Richard M. Smith v. United States of America, Counsel Stack Legal Research, https://law.counselstack.com/opinion/richard-m-smith-v-united-states-of-america-almd-2026.