Thompson v. USA- 2255

CourtDistrict Court, D. Maryland
DecidedDecember 17, 2024
Docket8:24-cv-01986
StatusUnknown

This text of Thompson v. USA- 2255 (Thompson v. USA- 2255) is published on Counsel Stack Legal Research, covering District Court, D. Maryland primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Thompson v. USA- 2255, (D. Md. 2024).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MARYLAND

KYLE S. THOMPSON, Petitioner, vy. Crim. Action No. TDC-17-0195 Civil Action No. TDC-24-1986 UNITED STATES OF AMERICA, Respondent.

' MEMORANDUM ORDER Self-represented Petitioner Kyle S. Thompson has filed a Motion to Vacate, Set Aside, or Correct the Sentence pursuant to 28 U.S.C. § 2255 in which he collaterally attacks his conviction and sentence based on a claim of newly discovered evidence. Having reviewed the submitted materials, the Court finds that no hearing is necessary. See Rule 8(a), Rules Governing Section 2255 Proceedings for the United States District Courts; D. Md. Local R. 105.6. For the reasons set forth below, the Motion will be DISMISSED. BACKGROUND “On September 13, 2018, Thompson was convicted after a jury trial on 18 counts of Production of Child Pornography, in violation of 18 U.S.C. § 2251(a). On February 4, 2019, the Court sentenced Thompson to a total of 5,040 months of imprisonment. On February 5, 2019, Thompson filed a notice of appeal to the United States Court of Appeals for the Fourth Circuit. On April 6, 2020, the Fourth Circuit affirmed Thompson’s conviction and sentence. On May 27, 2020, the Fourth Circuit denied Thompson’s petition for rehearing and rehearing en banc.

Thompson filed a petition for writ of certiorari with the United States Supreme Court on October 23, 2020. The Supreme Court denied the petition on December 7, 2020. On July 8, 2024, Thompson filed the present Motion to Vacate, Set Aside, or Correct the Sentence under 28 U.S.C. § 2255. In the Motion, Thompson argues that, following his conviction and sentencing, he was diagnosed with “Glioblastoma Multiforme Terminal Brain Cancer.” Mot. at 1, ECF No. 147. Thompson asserts that because this condition was not known until after conviction and sentencing, he was unable to raise it during trial, sentencing, or his direct appeals and that, had he been able to do so, he would have argued that he was not competent to stand trial, asserted a defense of “diminished moral culpability,” or invoked other defenses based on that condition. /d. at 1-2. DISCUSSION In responding to the Motion, the Government has argued that it is time-barred. After the Court granted Thompson additional time to file a reply brief and specifically directed him to “address the Government’s argument that his Motion is time-barred and, if so, whether there is a basis for equitable tolling to excuse the late filing,’ ECF No. 151, Thompson filed a timely reply brief on November 22, 2024 in which he argues that the Motion is a timely second and successive § 2255 motion because it is based on newly discovered evidence and also argues that equitable tolling is warranted. I. Legal Standard A federal prisoner may file a motion to vacate, set aside, or correct the sentence pursuant to 28 U.S.C. § 2255 on the basis that: (1) “the sentence was imposed in violation of the Constitution or laws of the United States”; (2) the sentencing court lacked jurisdiction; (3) the sentence exceeded the maximum authorized by law; or (4) the sentence is “otherwise subject to

collateral attack.” 28 U.S.C. § 2255(a). The prisoner bears the burden of proof and must establish the claim by a preponderance of the evidence. See Miller v. United States, 261 F.2d 546, 547 (4th Cir. 1958). In § 2255 proceedings, a hearing is necessary when there are material disputed facts or when the court must make a credibility determination in order to resolve the motion. See United States v. Witherspoon, 231 F.3d 923, 926-27 (4th Cir. 2000). However, “[i]f it plainly appears from the motion, any attached exhibits, and the record of prior proceedings that the moving party is not entitled to relief, the judge must dismiss the motion.” Rule 4(b), Rules Governing Section 2255 Proceedings for the United States District Courts. II. Statute of Limitations Under 28 U.S.C. § 2255, a petitioner has a one-year period in which to file a motion to vacate, set aside, or correct the sentence running from the latest of: (1) the date on which the judgment of conviction becomes final; (2) the date on which the impediment to making a motion created by governmental action in violation of the Constitution or laws of the United States is removed, if the movant was prevented from making a motion by such governmental action; (3) the date on which the right asserted was initially recognized by the Supreme Court, if that right has been newly recognized by the Supreme Court and made retroactively applicable to cases on collateral review; or (4) the date on which the facts supporting the claim or claims presented could have been discovered through the exercise of due diligence. 28 U.S.C. § 2255(f). Here, it is beyond dispute that Thompson’s Motion, filed on July 30, 2024, was filed more than one year after the date on which the judgment of conviction became final. See Clay v. United States, 537 U.S. 522, 527 (2003) (“Finality attaches when this Court affirms a conviction on the

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merits on direct review or denies a petition for a writ of certiorari, or when the time for filing a certiorari petition expires.”). Because the Supreme Court denied Thompson’s petition for writ of certiorari on December 7, 2020, the one-year limitations period ended on December 7, 2021, more than two years before Thompson’s filed this Motion. Thus, without more, the Motion is untimely. By asserting that his Motion is based on newly discovered evidence, specifically his cancer diagnosis, Thomas effectively argues that the one-year limitations period did not begin until “the date on which the facts supporting the claim or claims presented could have been discovered through the exercise of due diligence.” 28 U.S.C. § 2255(f)(4). However, Thompson acknowledges that he was aware of his diagnosis by October 2021 at the latest. See Reply at 1, ECF No. 153; Mot. at 2. Indeed, the record establishes that Thompson was diagnosed with “(mJalignant neoplasm of brain” on May 10, 2021, Health Report at 2, Mot. Ex. 3, ECF No. 147- 3, and that prior to October 18, 2021, he had already filed a request for a reduction in his sentence based on this condition, Mot. Ex. 2, ECF No. 147-2. Where by October 18, 2021 Thompson was aware of his diagnosis and had already determined that it could be invoked as a basis for additional legal challenges, the Court finds that the limitations period began to run no later than October 18, 2021, such that the one-year limitations period ended on October 18, 2022, nearly two years before Thompson filed the Motion. See 28 U.S.C. § 2255(f)(4). Finally, Thompson’s references to rules relating to second and successive § 2255 motions do not alter the analysis because the present Motion is Thompson’s first § 2255 motion.

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Related

Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
Clay v. United States
537 U.S. 522 (Supreme Court, 2003)
Pace v. DiGuglielmo
544 U.S. 408 (Supreme Court, 2005)
Edward Donald Miller v. United States
261 F.2d 546 (Fourth Circuit, 1958)
United States v. John Fitzgerald Prescott
221 F.3d 686 (Fourth Circuit, 2000)
United States v. Roderick Tyronda Witherspoon
231 F.3d 923 (Fourth Circuit, 2000)
Holland v. Florida
177 L. Ed. 2d 130 (Supreme Court, 2010)

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Thompson v. USA- 2255, Counsel Stack Legal Research, https://law.counselstack.com/opinion/thompson-v-usa-2255-mdd-2024.