Taylor v. United States

CourtDistrict Court, M.D. Florida
DecidedMarch 29, 2023
Docket8:21-cv-02326
StatusUnknown

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

Bluebook
Taylor v. United States, (M.D. Fla. 2023).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION

EVERETT TAYLOR,

Petitioner,

v. Case No. 8:21-cv-2326-WFJ-JSS

UNITED STATES OF AMERICA,

Respondent. /

ORDER

Before the Court is Everett Taylor’s (“Petitioner”) Motion to Vacate, Set Aside, or Correct Sentence pursuant to 28 U.S.C. § 2255 (Civ. Dkts. 1, 2, 8).1 The United States of America (“Respondent”) has responded in opposition (Civ. Dkt. 17), and Petitioner has replied (Civ. Dkts. 20 & 21). Upon careful review, the Court denies Petitioner’s Motion. BACKGROUND On October 16, 2013, a federal grand jury returned a twenty-six-count indictment against Petitioner for various crimes related to filing fraudulent tax returns. Cr. Dkt. 1. Petitioner opted to enter into a plea agreement instead of going

1 In this civil case, citations to the civil docket will be denoted as “Civ. Dkt. [document number].” Citations to Petitioner’s prior criminal case, 8:13-cr-496-WFJ-JSS-1, will be denoted as “Cr. Dkt. [document number].” to trial and pled guilty to theft of government property in violation of 18 U.S.C. § 641 (Count Seventeen) as well as aggravated identity theft in violation of 18 U.S.C.

§ 1028A (Count Twenty-Six). Cr. Dkt. 114 at 1. Petitioner also agreed to waive the right to appeal his sentence. Id. at 12–13. On July 3, 2017, the presiding court held a change-of-plea hearing. Cr. Dkt.

196. Petitioner affirmed his competency and stated his satisfaction with his attorney at this time. Id. at 6, 9–10. After reviewing Petitioner’s entire plea agreement and ascertaining Petitioner’s understanding of each provision, the court was satisfied that Petitioner knowingly and voluntarily entered into the agreement. Id. at 32. The court

therefore accepted Petitioner’s plea and adjudicated him guilty. Cr. Dkt. 116. Prior to sentencing, the Probation Office prepared a Presentence Investigation Report (“PSR”). Cr. Dkt. S-132. Although the base offense level for Count

Seventeen was 6, Petitioner received a 14-level enhancement for loss exceeding $550,000 (U.S.S.G. § 2B1.1(b)(1)(H)), a 2-level enhancement for offense conduct involving 10 or more victims (U.S.S.G. § 2B1.1(b)(2)(A)(i)), a 2-level enhancement for obstruction of justice (U.S.S.G. § 3C1.1), and a 2-level reduction for acceptance

of responsibility (USSG § 3E1.1(a)). Id. at 9–10. This resulted in a total offense level of 22. Id. at 10. Given Petitioner’s criminal history category of III, Petitioner’s advisory guideline range spanned from 51 to 63 months’ imprisonment for Count Seventeen followed by a consecutive 24-month term for Count Twenty-Six. Id. at 10, 22, 34.

Both Petitioner and Respondent objected to the PSR’s total offense level calculation. Petitioner argued that the total offense level was erroneously high for three reasons: 1) a 2-level § 2B1.1(b)(1)(H) enhancement for loss exceeding

$550,000 is inappropriate where the actual loss was approximately $300,000; 2) a 2-level § 2B1.1(b)(2)(A)(i) enhancement for offense conduct involving more than 10 victims is inappropriate where the only victim was the IRS; and 3) an additional 1-level § 3E1.1(a) and (b) reduction for acceptance of responsibility is appropriate

because the Petitioner accepted his plea agreement within a timely fashion. Id. at 41–42. Respondent argued that the total offence-level was erroneously low for two reasons: 1) a 2-level § 3E1.1(a) reduction for acceptance of responsibility is

inappropriate where Petitioner obstructed justice by absconding from pretrial supervision; and 2) an additional 2-level § 2B1.1(b)(11)(B)(i) enhancement is appropriate because the offense conduct involved production of an unauthorized access device or counterfeit access device. Id. at 38–40.2

The presiding court heard Respondent and Petitioner’s objections during Petitioner’s initial sentencing hearing. Cr. Dkt. 167. The court sustained both of

2 In addition to Petitioner’s aforementioned objections, Petitioner’s counsel filed a sentencing memorandum which requested a minor role reduction (U.S.S.G. § 3B1.2) and a downward variance based on various factors. Cr. Dkt. 135 at 2–6. Respondent’s objections and overruled each of Petitioner’s, resulting in a total offense level of 26 for Count Seventeen. Id. at 16–18. This raised the advisory

guidelines to a range of 78 to 97 months’ imprisonment for Count Seventeen with a consecutive 24-month term for Count Twenty-Six. Cr. Dkt. 170 at 6. The court ultimately sentenced Petitioner to 102 months’ imprisonment (78 months as to Count

Seventeen and a consecutive 24 months as to Count Twenty-Six). Cr. Dkt. 145. Notwithstanding Petitioner’s sentence appeal waiver, Petitioner timely appealed his sentence to the Eleventh Circuit Court of Appeals. Petitioner argued that Respondent breached an implicit promise in its plea agreement with Petitioner

by objecting to the offense level reduction for acceptance of responsibility and by failing to object to the offense level enhancement for obstruction of justice. Cr. Dkt. 199 at 4. Petitioner also raised various challenges to his sentence. Id.

The Eleventh Circuit afforded Petitioner no relief. Upon reviewing the record, the Eleventh Circuit found that “there is no substantial question as to whether [Respondent] breached [Petitioner’s] plea agreement” and that Petitioner’s sentence appeal waiver is valid and enforceable. Id. at 5–7. The Eleventh Circuit therefore

granted Respondent’s motion for summary disposition with respect to Petitioner’s breach-of-plea challenge as well as Respondent’s motion to dismiss Petitioner’s challenges to his sentence pursuant to the appeal waiver in his plea agreement. Id. at

7. On October 10, 2021, Petitioner timely filed the instant § 2255 Motion with an accompanying legal memorandum. Civ. Dkts. 1 & 2. Petitioner then filed an

amended motion on December 20, 2021. Civ. Dkt. 8. Collectively, Petitioner asserts four claims for ineffective assistance of counsel: 1) trial counsel failed to know the law and properly object to the application of § 2B1.1(b)(11)(B)(i); 2) appellate

counsel failed to properly address “the issue of contractual waiver” in Petitioner’s appellate brief, resulting in the Eleventh Circuit not considering the merits of Petitioner’s appeal; 3) trial counsel failed to know the law and properly challenge financial loss related to Petitioner’s § 2B1.1(b)(1)(H) enhancement; and 4) trial

counsel failed to know the law and properly challenge the number of victims related to Petitioner’s § 2B1.1(b)(2)(A) enhancement. Civ. Dkts. 1, 2, 8. STANDARD OF REVIEW

On collateral review, the petitioner “has the burden of proof and persuasion on all the elements of his claim.” In re Moore, 830 F.3d 1268, 1272 (11th Cir. 2016). This is “a significantly higher hurdle than would exist on direct appeal,” United States v. Frady, 456 U.S. 152, 164–66 (1982); for, “[w]hen the process of direct

review . . . comes to an end, a presumption of finality and legality attaches to the conviction and sentence” at issue. Moore, 830 F.3d at 1272 (citations omitted). “[I]f the Court cannot tell one way or the other” whether the petitioner’s claim is valid, the petitioner has “failed to carry his burden of showing all that is necessary to warrant § 2255 relief.” Id. at 1273.

DISCUSSION Counsel is ineffective under the Sixth Amendment if “(1) counsel’s performance was deficient; and (2) the deficient performance prejudiced the defense

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Taylor v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/taylor-v-united-states-flmd-2023.