THOMAS v. United States

CourtDistrict Court, D. New Jersey
DecidedSeptember 30, 2022
Docket2:19-cv-12501
StatusUnknown

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

Bluebook
THOMAS v. United States, (D.N.J. 2022).

Opinion

NOT FOR PUBLICATION

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

: HAKIM THOMAS, : : Civil Action No. 19-12501 (CCC) Petitioner, : : v. : OPINION : UNITED STATES OF AMERICA, : : Respondent. : :

CECCHI, District Judge

Before the Court are pro se petitioner Hakim Thomas’s motions to vacate, set aside, or correct a sentence pursuant to 28 U.S.C. § 2255 (ECF Nos. 1, 7, 13).1 In 2015, Thomas pleaded guilty to drug-related offenses. In 2017, he was sentenced to 108 months’ imprisonment. Thomas asserts violations of his Sixth Amendment right to effective assistance of counsel at sentencing. Specifically, he alleges counsel: (1) failed to object to the sentencing court’s insufficient consideration, or improper weighing, of the 18 U.S.C. § 3553(a) sentencing factors, and (2) failed to call the sentencing court’s attention to two co-defendants who purportedly committed similar

1 The Court entered the following order on May 13, 2019: “within forty-five (45) days of the date of this Order, Petitioner shall either notify the Court in writing that he intends to have his pending section 2255 Motion considered as his all-inclusive section 2255 motion, or submit an amended section 2255 motion, which includes all available federal claims; the Clerk of the Court shall send a copy of this Memorandum Order to Petitioner at the address on file.” ECF No. 4. In response to this order, Petitioner submitted a motion to vacate, set aside, or correct his sentence pursuant to section 2255 (ECF No. 7), and what has been docketed as a “motion to amend” (ECF No. 13). Upon review, Petitioner’s “motion to amend” advances substantive arguments advocating for a change to his sentence and does not appear to seek leave to amend. Accordingly, the Court considers Petitioner’s “motion to amend” as a second motion to vacate, set aside, or correct his sentence pursuant to section 2255. The Court has considered both these submissions (ECF Nos. 7, 13), as well as his originally filed motion (ECF No. 1). offenses but were sentenced to shorter terms of imprisonment. Thomas argues that these failures caused the sentencing judge, the Honorable William H. Walls, to commit procedural sentencing errors, resulting in a substantively unreasonable sentence. Thomas’s additional motion to vacate his sentence reiterates these arguments and includes additional detail regarding, inter alia, the timeliness of his section 2255 motion. ECF No. 13.

For the following reasons, Thomas’s section 2255 motions (ECF Nos. 1, 7, 13) are denied, and Thomas is denied a certificate of appealability. I. Factual Background and Procedural History A. The Underlying Criminal Case In May 2015, the Government filed a criminal complaint charging Thomas with possession and distribution of heroin. See No. 16-cr-456 (D.N.J.) (ECF No. 1). He was arrested in August 2015 (id. at ECF Entry dated 8/28/15), and in October 2015, he waived indictment and pleaded guilty pursuant to a plea agreement to a one-count information charging him with knowingly possessing and distributing a substance containing a cocaine base, in violation of 21 U.S.C. §§

841(a)(1) and 841(b)(1)(C). Id. at ECF Nos. 17 (Information); 18 (Waiver of Indictment); 19 (Guilty Plea); 21 (Plea Agreement); see also A18.2 Thomas stipulated in his plea agreement that he had two previous state court convictions for controlled-substance distribution and second- degree robbery, but reserved the right to argue at sentencing that these convictions did not qualify him as a career offender under U.S.S.G. § 4B1.1. A25.

2 References to “A” in this Opinion are to the appendix filed in Thomas’s appeal of the underlying criminal matter to the United States Court of Appeals for the Third Circuit (Case No. 17-1792), which is attached as Exhibit 2 to the Government’s letter brief in response to Thomas’s § 2255 motion. See ECF No. 17, Ex. 2 (Exhibit 2 includes the district court docket, Thomas’s plea agreement, the sentencing transcript, the Government’s sentencing memorandum, and defense counsel’s sentencing memorandum). The Presentence Report (ECF No. 17-1 (“PSR”)) noted that Thomas qualified as a career offender due to his felony convictions. PSR at ¶¶ 33–34. This designation increased Thomas’s criminal history category from III to VI and increased his base offense level from 12 to 32. Id. at ¶¶ 34, 43–44. Taken together with a downward adjustment for acceptance of responsibility, which resulted in a total offense level of 29, Thomas’s criminal history score yielded an advisory

Sentencing Guidelines range of 151 to 188 months’ imprisonment. PSR at ¶¶ 35–37, 78. Thomas and the Government submitted memoranda prior to sentencing. A82–87 (“Thomas Sentencing Br.”), A88–100 (“Gov’t Sentencing Br.”). Thomas objected to a career offender enhancement, arguing that it substantially overrepresented his criminal history and the likelihood of his recidivism because he was eighteen at the time of his robbery conviction and did not serve prison time in connection with his past drug conviction. A82–83. Alternatively, Thomas argued that, even if he did qualify as a career offender, a sentence between 10 and 16 months—the Guidelines range he would have faced but for the career offender designation—was warranted to ensure a sentence not greater than necessary to satisfy the statutory directives set forth in 18 U.S.C.

§ 3553. A84–87. Such a term, he argued, was “more than adequate to provide deterrence for [Thomas] and others similarly situated.” A86. The Government opposed and asked for a sentence within the PSR’s calculated Guidelines range of 151 to 188 months. A88. At Thomas’s sentencing on March 29, 2017, the Court adopted the PSR’s recommendations, including its determination that Thomas qualified as a career offender. A49– 50, A77. The court then “depart[ed]” downward from Thomas’s original offense level of 29 to an offense level of 24, and imposed a below-Guidelines sentence of 108 months’ imprisonment followed by a three-year term of supervised release.3 Id. at A77–78. B. Third Circuit Appeal On direct appeal, Thomas argued that the sentencing court procedurally erred by treating the Sentencing Guidelines as mandatory and failing to adequately explain its rationale for imposing

the 108-month sentence. See United States v. Thomas, 723 F. App’x 114, 115 (3d Cir. 2018). Thomas also argued that the procedural errors led to a substantively unreasonable sentence. Id. The Third Circuit rejected these arguments finding no support for Thomas’s assertion that the sentencing court erroneously treated the Guidelines as mandatory. Id. at 117–18. The Court stated: . . . Thomas maintains that the District Court “seemed to ignore that the [G]uidelines are advisory, not mandatory,” and accordingly felt “obligated” to find that Thomas was a career offender on account of his two prior felony offenses. The record belies Thomas’s assertion. “A district court should begin all sentencing proceedings by correctly calculating the applicable Guidelines range.” United States v. Wise, 515 F.3d 207, 216 (3d Cir. 2008). Here, the District Court did just that, stating at the very beginning of the sentencing hearing that it was “prepared to adopt” the PSR’s Guidelines calculations, i.e., that Thomas had a net base offense level of 29 and criminal history category of VI. The District Court then engaged in lengthy colloquies with defense counsel and Thomas himself about Thomas’s criminal history and personal background.

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