Smith v. United States of America (INMATE 3)

CourtDistrict Court, M.D. Alabama
DecidedMarch 30, 2020
Docket2:17-cv-00270
StatusUnknown

This text of Smith v. United States of America (INMATE 3) (Smith v. United States of America (INMATE 3)) 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
Smith v. United States of America (INMATE 3), (M.D. Ala. 2020).

Opinion

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

MICHAEL SMITH, ) ) Petitioner, ) ) Civil Action No. v. ) 2:17cv270-MHT ) [WO] UNITED STATES OF AMERICA, ) ) Respondent. )

RECOMMENDATION OF THE MAGISTRATE JUDGE

Before the court is Michael Smith’s (“Smith”) motion to vacate, set aside, or correct sentence under 28 U.S.C. § 2255. CIV Doc. # 1.1 Upon review, the court concludes that Smith’s § 2255 motion should be denied without an evidentiary hearing. I. BACKGROUND The case against Smith arose from the August 2010 beating death of Rocrast Mack, an Alabama inmate at the Ventress Correctional Facility (“Ventress”), at the hands of three Ventress correctional officers, including Smith, a lieutenant at the prison. The other correctional officers implicated in the incident pled guilty to various charges, while Smith went to trial on civil-rights charges involving Mack’s death and the subsequent cover-up.

1 References to document numbers assigned by the Clerk in this civil action, Civil Action No. 2:17-CV-270-MHT, are designated as “CIV Doc. #.” References to document numbers assigned by the Clerk in the underlying criminal case, Case No. 2:12-CR-48-MHT, are designated as “CR Doc. #.” Pinpoint citations are to the page of the electronically filed document in the court’s CM/ECF filing system, which may not correspond to pagination on the “hard copy” of the document presented for filing In June 2013, a jury found Smith guilty of two counts of deprivation of civil rights resulting in bodily injury and death, in violation of 18 U.S.C. § 242; one count of obstruction of

justice for persuading others to engage in misleading conduct, in violation of 18 U.S.C. § 1512(b)(3); two counts of obstruction of justice for misleading conduct, in violation of 18 U.S.C. § 1512(b)(3); one count of conspiracy to obstruct justice, in violation of 18 U.S.C. § 1512(k); one count of obstruction of justice for falsifying documents, in violation of 18 U.S.C. § 1519; and one count of making false statements to the FBI, in violation of 18 U.S.C. § 1001.

On November 4, 2013, following a multiday sentencing hearing, the district court sentenced Smith to 30 years in prison, consisting of 30 years for each of the two civil-rights counts and 20 years for each remaining count, all terms to run concurrently. The district court entered its judgment on November 22, 2013. Smith appealed, claiming the district court erred by (1) denying his motion to

suppress his post-incident statements, which he argued were protected under Garrity v. New Jersey, 385 U.S. 493 (1967); (2) denying his request for a hearing as provided in Kastigar v. United States, 406 U.S. 441 (1972); and (3) imposing a procedurally unreasonable sentence based upon the misapplication of the sentencing guidelines. CIV Doc. # 9-23.

On April 29, 2016, the Eleventh Circuit issued an opinion rejecting Smith’s arguments and affirming his convictions and sentence. United States v. Smith, 821 F. 3d 1293 (11th Cir. 2016). Smith filed a petition for writ of certiorari with the United States Supreme Court, which denied certiorari review on January 9, 2017. CIV Doc. # 9-25. On April 26, 2017, Smith, acting pro se, filed this § 2255 motion asserting the following claims:

1. Trial counsel was ineffective for failing to challenge the sufficiency of the evidence to support Smith’s convictions.

2. Counsel was ineffective for failing to object to or move to strike Smith’s post-incident statements to Alabama investigatory agencies based on Garrity v. New Jersey, 385 U.S. 493 (1967).

3. Counsel was ineffective for failing to call favorable witnesses at trial.

4. Counsel was ineffective for failing to have Scottie Glenn’s testimony excluded.

5. Counsel was ineffective for failing to object to the district court’s misleading and vague jury instructions.

6. Counsel was ineffective for failing to seek mitigation at sentencing.

7. Counsel was ineffective for failing to seek a preliminary hearing.

8. Counsel was ineffective for failing to challenge the grand jury pool.

9. Counsel was ineffective for failing to request a competency hearing for Smith.

10. Counsel was ineffective for failing to consult with Smith before filing the appeal.

11. The district court erred in denying Smith’s pretrial motions under Garrity and Kastigar v. United States, 406 U.S. 441 (1972).

12. The district court erred by refusing to give a jury instruction on manslaughter.

CIV Doc. # 1 at 4–8; CIV Doc. # 1-1 at 6–18. II. DISCUSSION A. General Standard of Review Because collateral review is not a substitute for direct appeal, the grounds for collateral attack on final judgments under 28 U.S.C. § 2255 are limited. A prisoner may

have 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) (citations omitted). B. Claims of Ineffective Assistance of Counsel A claim of ineffective assistance of counsel is evaluated under the two-part test

announced in Strickland v. Washington, 466 U.S. 668 (1984). An attorney is considered constitutionally ineffective if (1) his “performance was deficient” and (2) that “deficient performance prejudiced the defense.” Strickland, 466 U.S. at 687. See Chandler v. United States, 218 F.3d 1305, 1313 (11th Cir. 2000). Scrutiny of counsel’s performance is highly deferential, and the court indulges a

strong presumption that counsel’s performance was reasonable. Chandler, 218 F.3d at 1314 (internal quotation marks omitted). The court will “avoid second-guessing counsel’s performance: It does not follow that any counsel who takes an approach [the court] would not have chosen is guilty of rendering ineffective assistance.” Id.

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Bluebook (online)
Smith v. United States of America (INMATE 3), Counsel Stack Legal Research, https://law.counselstack.com/opinion/smith-v-united-states-of-america-inmate-3-almd-2020.