Trejo v. United States of America (INMATE 3)

CourtDistrict Court, M.D. Alabama
DecidedAugust 15, 2019
Docket2:16-cv-00647
StatusUnknown

This text of Trejo v. United States of America (INMATE 3) (Trejo 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
Trejo v. United States of America (INMATE 3), (M.D. Ala. 2019).

Opinion

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

ALBERTO TREJO, ) ) Petitioner, ) ) Civil Action No. v. ) 2:16cv647-MHT ) (WO) UNITED STATES OF AMERICA, ) ) Respondent. )

RECOMMENDATION OF THE MAGISTRATE JUDGE

Before the court is Petitioner Alberto Trejo’s (“Trejo”) pro se motion under 28 U.S.C. § 2255 to vacate, set aside, or correct sentence. Doc. # 1.1 I. BACKGROUND On October 7, 2014, Trejo pleaded guilty to conspiracy to distribute and possess with intent to distribute at least 500 grams of methamphetamine, in violation of 21 U.S.C. §§ 841(a)(1) & 846. Doc. # 7-4. After a sentencing hearing that began on January 6, 2015, and carried over to January 7, the district court sentenced Trejo to 360 months’ imprisonment, to run consecutively to a state sentence Trejo was serving when he committed his federal offense. Docs. # 7-8 & 7-9. Trejo appealed, arguing that (1) his sentence was procedurally unreasonable because the district court erroneously believed it could not downwardly vary from the

1 References to document numbers (“Doc. #”) are to the pleadings, motions, and other materials in the court file as designated by the Clerk of Court on the docket sheet in this civil action. 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. methamphetamine guidelines based on a policy disagreement with those guidelines, and (2) his sentence was substantively unreasonable because it was based on those guidelines, which are unduly harsh and unsupported by empirical evidence. Doc. # 7-12. On August

24, 2015, the Eleventh Circuit issued an opinion affirming Trejo’s conviction and sentence. Doc. # 7-13; see United States v. Trejo, 624 F. App’x 709 (11th Cir. 2015). Trejo did not seek certiorari review in the Supreme Court. On August 8, 2016, Trejo filed this § 2255 motion asserting the following claims: 1. His sentence was procedurally unreasonable because the district court erroneously believed it could not downwardly vary from the methamphetamine guidelines based on a policy disagreement with those guidelines.

2. The district court committed a clear error in judgment in weighing the 18 U.S.C. § 3553(a) factors by arriving at a sentence outside the range of a reasonable sentence dictated by the facts of the case.

3. The methamphetamine guidelines are flawed because the disparity in punishment meted out under its provision based solely on drug purity is not supported by research.

4. The criminal charges against him were completely dismissed when the original indictment was dismissed after a superseding indictment was brought.

5. His lawyers provided ineffective assistance of counsel.

Doc. # 1 at 4-8. The Government filed a response on October 5, 2016, arguing that Trejo’s four substantive, non-ineffective assistance of counsel claims are procedurally defaulted because the first three claims were decided adversely to Trejo on direct appeal and the fourth claim could have been raised in the trial court and on appeal, but was not. Doc. # 7 at 21–25. The government further argued that Trejo did not meet his burden of pleading deficient performance and prejudice regarding his ineffective assistance of counsel claim. See Doc. # 7 at 25–31.

On December 2, 2016, Trejo filed a reply to the Government’s response in which he asserted additional claims of ineffective assistance of counsel not presented in his § 2255 motion. Doc. # 13.2 This court deemed Trejo’s reply to contain an amendment to his § 2255 motion adding claims that his counsel was ineffective for failing to (a) move to suppress evidence; (b) file a speedy trial motion; (c) file a motion to compel discovery; (d)

file a motion for a mental and psychological evaluation; (e) challenge the use of his prior convictions in determining his sentence; and (f) present additional mitigating evidence at sentencing. See Doc. # 13 at 8–17. Under this court’s orders, the Government filed a response to Trejo’s amendment arguing that his new claims of ineffective assistance of counsel should be dismissed as

time-barred under 28 U.S.C. § 2255(f) and that, even if timely, none of the new claims established deficient performance by counsel and resulting prejudice under the standard of Strickland v. Washington, 466 U.S. 668, 694 (1984). Doc. # 17 at 2–19. For the reasons that follow, the undersigned recommends that Trejo’s § 2255 motion be denied without an evidentiary hearing and that this action be dismissed with prejudice.

2 Although Trejo’s reply containing the new claims of ineffective assistance of counsel was date- stamped as received in this court on December 8, 2016, Trejo certified that he mailed the reply on December 2, 2016. See Doc. # 13 at 20. Assuming that Trejo mailed the reply from prison, this court applies the prison mailbox rule to find the reply to have been filed on December 2, 2016. See Houston v. Lack, 487 U.S. 266, 271–72 (1988); Washington v. United States, 243 F.3d 1299, 1301 (11th Cir. 2001). See Rule 8(a), Rules Governing Section 2255 Proceedings in the United States District Courts. 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. Procedurally Barred Claims 1. Claims Raised and Decided On Direct Appeal Trejo’s § 2255 motion includes claims that (1) his sentence was procedurally

unreasonable because the district court erroneously believed it could not downwardly vary from the methamphetamine guidelines based on a policy disagreement with those guidelines; (2) the district court committed a clear error in judgment in weighing the 18 U.S.C. § 3553

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Bluebook (online)
Trejo v. United States of America (INMATE 3), Counsel Stack Legal Research, https://law.counselstack.com/opinion/trejo-v-united-states-of-america-inmate-3-almd-2019.