Shipley v. United States

CourtDistrict Court, D. Arizona
DecidedNovember 3, 2020
Docket4:20-cv-00268
StatusUnknown

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

Bluebook
Shipley v. United States, (D. Ariz. 2020).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Marc Ryan Shipley, No. CV-20-00268-TUC-DCB

10 Petitioner, CR 16-01061-TUC-DCB (JR)

11 v. ORDER

12 United States of America,

13 Respondent. 14 15 Movant, Defendant Marc Ryan Shipley, files a Petition under 28 U.S.C. § 2255, to 16 Vacate, Set Aside, or Correct Sentence by a Person in Federal Custody (the Petition). The 17 Court denies the Petition for all the reasons explained by the Government in its Response. 18 (Doc. 4.) 19 On January 31, 2018, a jury convicted the Defendant of three counts of possession 20 of firearms and ammunition by a convicted felon in violation of 18 U.S.C. § 922(g)(1). The 21 Court sentenced him to 96 months in prison on each count, to run concurrently, followed 22 by three years of supervised release. 23 The Defendant appealed his conviction. The Ninth Circuit Court of Appeals denied 24 the appeal, a petition for rehearing and rehearing en banc, and entered the Mandate on 25 August 16, 2019, affirming the convictions. On June 22, 2020, the Defendant/Movant filed 26 this habeas Petition, pursuant to 28 U.S.C. § 2255. (Doc. 1.) On September 4, 2020, the 27 Government filed a Response. (Doc. 4.) Movant did not file a Reply. The Court denies the 28 habeas Petition for all the reasons explained by the Government in the Response. The bulk 1 of the arguments raised in the Petition are procedurally precluded, and two fail on the 2 merits. 3 Motion Under 28 U.S.C. § 2255 4 Pursuant to 28 U.S.C. § 2255, a petition for writ of habeas corpus should be 5 presented to the court which imposed the allegedly improper judgment of conviction and 6 sentence. 28 U.S.C. § 2255. According to Rule 4(a) of the Rules Governing Section 2255 7 Proceedings, the petition shall be directed to the judge who sentenced the petitioner. 8 Therefore, this Court considers the merits of the pending Petition. 9 When a § 2255 motion is made, "[u]nless the motion and the files and records of 10 the case conclusively show that the prisoner is entitled to no relief, the court shall ... grant 11 a prompt hearing thereon." 28 U.S.C. § 2255. The standard is whether the Movant has 12 made specific factual allegations that, if true, state a claim on which relief could be granted. 13 United States v. Hearst, 638 F.2d 1190, 1194 (9th Cir.1980). A hearing must be granted 14 unless the allegations, when viewed against the record, do not state a claim for relief or are 15 so palpably incredible or patently frivolous as to warrant summary dismissal. Blackledge 16 v. Allison, 431 U.S. 63, 76 (1977); Baumann v. United States, 692 F.2d 565, 571, 581 (9th 17 Cir.1982). 18 Movant alleges nine grounds for relief under 28 U.S.C. § 2255 in the habeas 19 Petition. In Ground One, he alleges that Rehaif v. United States, 139 S. Ct. 2191 (2019), 20 applies to his case retroactively. In Ground Two, he alleges that his attorneys were 21 ineffective in reviewing and explaining the plea agreement. In Ground Three, Movant 22 asserts a Fourth Amendment violation. In Ground Four, he alleges that his double 23 jeopardy rights were violated. In Ground Five, Movant claims his attorney failed to meet 24 with him before filing a response regarding the pretrial sentencing report and counsel 25 failed to address inaccuracies in the report. In Ground Six, Petitioner asserts a violation 26 under Brady v. Maryland, 373 U.S. 83 (1963). In Ground Seven, Movant claims that 27 counsel rendered ineffective assistance concerning restoration of his right to possess 28 firearms. In Ground Eight, he alleges that agents obtained warrants based upon false 1 statements. In Ground Nine, he alleges counsel repeatedly failed to file motions pursuant 2 to Franks v. Delaware, 438 U.S. 154 (1978). 3 The Movant relies on new law, Rehaif v. United States, 139 S.Ct. 2191 (2019), 4 which was decided after his appeal. The Supreme Court held that in a firearm case 5 prosecuted under 18 U.S.C. § 922(g), the Government must prove defendant’s knowledge 6 of the circumstance that causes him to be prohibited from possessing firearms and 7 ammunition. Id. at 2200. Movant argues that Rehaif supports his defense at trial that he 8 did not know he was illegally in possession of a firearm because he believed his right to 9 bear arms had been reinstated by a state court order. The Court rejected this argument 10 because the state court issued this Order on December 14, 2006, prior to the 2008 federal 11 felony conviction relied on by the Government as the predicate felony element for the § 12 922(g) offense. Additionally, the Court reviewed the transcript and minute entry from the 13 state proceeding and found that Judge Bryson told the defendant he had no jurisdiction to 14 restore Defendant’s right to possess guns pursuant to federal law. 15 In the context of the Movant’s argument that he didn’t know he could not legally 16 possess a firearm, Rehaif does not aid him. The Supreme Court did not change the generally 17 accepted rule that a mistake of law is not a defense to criminal activity. It remains true that 18 the Government need only prove that the Defendant consciously possessed what he knew 19 to be a firearm, and there is no requirement to know his possession is unlawful. Similarly, 20 under Rehaif, the Government need only prove that the Defendant knew he was a member 21 of one of the nine categories of individuals prohibited from receiving, shipping, 22 transporting, or possessing firearms and ammunition, including being a convicted felon. 18 23 U.S.C. § 922(g)(1). Prior to Rehaif the Government only had to prove knowledge related 24 to possessing the firearm, not knowledge of the felony conviction, which requires a 25 showing by uncontroverted evidence that a defendant was sentenced to more than a year 26 in prison. 27 Here, the parties stipulated that the defendant had previously been convicted of a 28 crime punishable by imprisonment for a term exceeding one year, i.e., a felony. The 1 Government did not prove the Defendant knew he was a convicted felon. As explained in 2 the Response to the 2255 habeas Petition, the Movant cannot show that refusing to correct 3 this error would result in a miscarriage of justice because on a retrial, the Government 4 could show that he was sentenced to 24 months in prison and served at least 21 months in 5 prison for these convictions. (Response (Doc. 4) at 8 (citing Presentence Report ¶ 37)).

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Related

Brady v. Maryland
373 U.S. 83 (Supreme Court, 1963)
Blackledge v. Allison
431 U.S. 63 (Supreme Court, 1977)
Franks v. Delaware
438 U.S. 154 (Supreme Court, 1978)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
United States v. Patricia Campbell Hearst
638 F.2d 1190 (Ninth Circuit, 1981)
Marcus T. Baumann v. United States
692 F.2d 565 (Ninth Circuit, 1982)
United States v. Gregory S. Brebner
951 F.2d 1017 (Ninth Circuit, 1991)
United States v. Samir Benamor
937 F.3d 1182 (Ninth Circuit, 2019)
Rehaif v. United States
588 U.S. 225 (Supreme Court, 2019)

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Shipley v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/shipley-v-united-states-azd-2020.