Scott Arlis Thomas v. United States of America

District Court, D. Idaho·Decided June 18, 2026·No. 1:23-cv-00404·Unknown

Opinion

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF IDAHO

SCOTT ARLIS THOMAS, Case Nos. 1:23-cv-00404-BLW 1:20-cr-00220-BLW Defendant-Movant,

v. MEMORANDUM DECISION AND ORDER UNITED STATES OF AMERICA,

Plaintiff-Respondent.

Scott Arlis Thomas (Defendant) filed a Motion to Vacate Sentence under 28 U.S.C. § 2255. The Court earlier considered the briefing, entered a notice of intent to rule on the § 2255 motion, and requested supplementation. Civ. Dkt. 21. Defendant’s “Chirp” messages (jail-monitored text messages) and medical records from his jail stay were subpoenaed and received. Civ. Dkt. 24, 32. The Court has reviewed the parties’ supplements (Dkts. 30, 33, 36, 37) and concludes that the § 2255 Petition is subject to denial. 1. Claims Previously Determined to be Subject to Denial

The Court earlier gave the parties notice that the following claims were subject to dismissal based on the § 2255 motion, supporting documents, and the record in the criminal and civil action: • Claim1(A) Unidentified factual mistakes were made at the bench trial, causing his plea not to be knowing or voluntary.

• Claim 1(C) There was an agreement that he could appeal the suppression motion denial. • Claim 1(D) He was threatened with the possibility of increased sentences, including consequences of the Payette County case. • Claim 1(E). The Court noticed that Defendant was answering questions inappropriately, causing the Court to notice something was off or it had a bad feeling about Defendant’s answers. • Claims 2(A) Ineffective Assistance of Counsel (IAC): Conflict of Interest in Federal Defender Services of Idaho (FDSI) office.

• Claim 2(B) IAC: Failure to Investigate Change in Jeffrey Jack Ellis testimony about whether Defendant rented garage 5.

• Claim 2(C) IAC: Failure to Correct Factual Mistakes in Presentence Report. • Claim 2(D) IAC: Failure to Request a § 5K2.12 “Duress” Departure. • Claim 3(A)(i) Law Enforcement Misconduct: Payette County Officers. • Claim 3(A)(ii) Law Enforcement Misconduct: Search-related Misconduct. • Claim 3(A)(iii) Law Enforcement Misconduct: Task Force. • Claim 3(A)(iv) Law Enforcement Misconduct: Silencer Testing. • Claim 3(B)(i) Prosecutorial Misconduct: Vindictive Superseding Indictment. • Claim 3(B)(ii) Prosecutorial Misconduct: Eliciting False Testimony. • Claim 3(B)(iii) Prosecutorial Misconduct: Failure to Disclose Officer Misconduct. • Claim 3(B)(iv) Prosecutorial Misconduct: Late Disclosure of Test Results and Presenting False Testimony. • Claim 3(B)(v) Prosecutorial Misconduct: Vindictive Prosecution re: Length of Sentence.

• Claim 4(A): Actual Innocence: Silencer Conviction. • Claim 4(B): Actual Innocence: Ammunition Conviction. • Claim 5: Equitable Estoppel: Silencer Conviction.

In the supplemental briefing, Defendant provides additional argument on his actual innocence claim. Dkt. 33 at 8-15. He argues that “the interpretation of the firearm statute is so overbroad and vague that it is unconstitutional.” Actual innocence, however, is factual innocence, not legal insufficiency. Bousley v. United States, 523 U.S. 614, 623 (1998)). Nothing in his supplement convinces the Court that this is a ground for § 2255 relief. To the extent Defendant has provided additional argument in support of any of these claims, the Court rejects those arguments. For the reasons set forth in the Notice of Intent to Rule, the Court denies and dismisses these claims because the

record conclusively shows that Defendant is not entitled to relief. 2. Two Remaining Claims The parties were ordered to submit additional supporting or rebuttal evidence or affidavits to address two ineffective assistance of counsel claims, which they have done. The Court has reviewed the supplements.

A. Standard of Law A defendant is entitled to effective assistance of counsel at all “critical stages” of the criminal process, including pretrial, arraignments, post-indictment interrogations, post-indictment lineups, and the entry of a guilty plea. Missouri v. Frye, 566 U.S. 134, 145 (2012). “Effective assistance” is defined by Strickland v. Washington, 466 U.S. 668 (1984). Strickland dictates that, to succeed on an ineffective assistance claim, a petitioner

must show that (1) counsel’s performance was deficient in that it fell below an objective standard of reasonableness, and that (2) the petitioner was prejudiced by the deficient performance. Id. at 684. In assessing trial counsel’s performance under Strickland’s first prong, a reviewing court must view counsel’s conduct at the time that the challenged act or omission occurred, making an effort to eliminate the distorting lens of hindsight. Id. at

689. The court must indulge in the strong presumption that counsel’s conduct fell within the wide range of reasonable professional assistance. Id. A petitioner asserting ineffective assistance of counsel must show that “counsel made errors so serious that counsel was not functioning as the ‘counsel’ guaranteed the defendant by the Sixth Amendment.” Id. at 687.

In assessing prejudice under Strickland’s second prong, a court must find that, under the particular circumstances of the case, there is a reasonable probability that, but for counsel’s errors, the result of the proceeding would have been different. Id. at 684, 694. A reasonable probability is one sufficient to undermine confidence in the outcome. Id. at 694.

A petitioner must establish both deficient performance and prejudice to prove an ineffective assistance of counsel claim. 466 U.S. at 697. The court may consider either prong of the Strickland test first, or it may address both prongs, even if one is deficient and will compel denial. Id. The Strickland standard is “highly demanding” and requires consideration of counsel’s “overall performance throughout the case,” Kimmelman v. Morrison, 477 U.S.

365, 382; 386 (1986), and “the totality of the evidence before the judge or jury,” Strickland, 466 U.S. at 695. B. Discussion of COVID-19 Claim Claim 1(B) is that Defendant was suffering from the effects of COVID-19 and could not think straight during the stipulated trial, causing his agreement to the terms to be unknowing and involuntary, but trial counsel failed to take steps to continue the trial

or do anything else. Defendant was represented by attorney Mark Ackley, the first assistant for the Federal Defender Service of Idaho (FDSI). See Civ. Dkt. 14-1. As a matter of defense strategy, rather than negotiate a plea agreement where Defendant would admit to guilt, Mr. Ackley negotiated a stipulation (Dkt. 45) that required the Court to make a ruling that

Defendant was guilty of the crimes charged based on the parties’ stipulated law and facts (“the trial”). As a result of the stipulation, Defendant’s right to appeal any sentence above 120 months would be preserved, but all other appellate rights (including the motion to suppress) would be waived. Dkt. 72 at 6.1 The trial was held on January 31, 2022. Dkt. 71. The Court reviews the transcript

1 Originally, the parties agreed that Defendant could appeal the suppression issues at the time Defendant entered the Stipulation for the bench trial. However, he subsequently reached an agreement with the Government whereby he would waive the right to appeal in return for the Government’s agreement to recommend concurrent 10 year sentences. When that agreement was put on the record at the sentencing hearing, Defendant did not object. Crim. Dkt. 71 at 5-20.

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Related

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