United States of America v. Kevin Carney

CourtDistrict Court, W.D. Pennsylvania
DecidedApril 16, 2026
Docket2:25-cv-00789
StatusUnknown

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

Bluebook
United States of America v. Kevin Carney, (W.D. Pa. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA

UNITED STATES OF AMERICA, ) ) Nos. 2:21-cr-228-1-RJC ) 2:25-cv-789-RJC ) v. ) ) Judge Robert J. Colville KEVIN CARNEY, ) )

MEMORANDUM OPINION Robert J. Colville, United States District Judge Before the Court is a Motion to Set Aside, Vacate, or Correct Sentence (ECF No. 250)1 (“Motion to Vacate”) filed by Defendant Kevin Carney. All deadlines for the filing of any further briefing have passed. Accordingly, the Court considers Defendant’s Motion to Vacate to be fully briefed and ripe for disposition. I. Background On February 24, 2022, Defendant pled guilty to Count 1 of the Indictment in his criminal case, which charged him with Conspiracy to Commit Mail and Wire Fraud in violation of 18 U.S.C. Section 1349. The court accepted Defendant’s plea and adjudged him guilty of the charged offense. In addition to Defendant’s entrance of a guilty plea at Count 1, he also acknowledged responsibility for the conduct charged in Counts 2 through 6, each of which charged Defendant with wire fraud, and, pursuant to a plea agreement, stipulated that the conduct charged in those counts could be considered by the Probation Office or the Court in calculating the guideline range and in imposing a sentence. On March 11, 2025, this Court sentenced Defendant to 30 months’

1 For ease of reference, the Court cites only to the documents filed in Defendant’s criminal case, but notes that a parallel civil docket has been opened at 2:25-cv-789. imprisonment and 3 years of supervised release at Count 1, and dismissed the remaining counts on the Government’s Motion. Defendant filed the Motion to Vacate on June 10, 2025, along with a Motion to Appoint Counsel (ECF No. 251). The Court denied the Motion to Appoint Counsel via Memorandum

Order (ECF No. 252) on June 13, 2025, and also filed a Miller Notice and Order (ECF No. 253) informing Defendant of the fact that the Court had received the Motion to Vacate, which the Court construed to seek relief under 28 U.S.C. § 2255. The Notice and Order further notified Defendant that federal law required him to include all federal constitutional claims challenging a specific conviction in one habeas corpus petition, and informed him that he could proceed via one of three options: (1) withdraw his petition and file a new one; (2) file an amendment within 120 days; or (3) choose to have the petition ruled on as filed. The Order required Defendant to notify the Court of his intention within 30 days. Defendant did not file a statement of intent. Accordingly, the Court entered an Order (ECF No. 260) on July 17, 2025 stating that Defendant’s Motion to Vacate would be ruled on as filed, and that Defendant thus lost his ability to file a second or successive

petition absent certification by the United States Court of Appeals for the Third Circuit. The Government filed a Response (ECF No. 265) to the Motion to Vacate on August 25, 2025, and the Transcript of the Sentencing Hearing (ECF No. 289) in this matter was docketed on December 10, 2025. II. Legal Standard A prisoner in federal custody may move to vacate his or her sentence under 28 U.S.C. § 2255 if such “sentence was imposed in violation of the Constitution or laws of the United States.” 28 U.S.C. § 2255(a). As a collateral challenge, a motion under § 2255 is “reviewed much less favorably than a direct appeal of the sentence.” United States v. Travillion, 759 F.3d 281, 288 (3d Cir. 2014). Section 2255 relief “is available only when ‘the claimed error of law was a fundamental defect which inherently results in a complete miscarriage of justice, and . . . present[s] exceptional circumstances where the need for the remedy afforded by the writ . . . is apparent.’” Id. (quoting Davis v. United States, 417 U.S. 333, 346 (1974)). The Supreme Court has explained

that “[h]abeas review is an extraordinary remedy and ‘will not be allowed to do service for an appeal.’” Bousley v. United States, 523 U.S. 614, 621 (quoting Reed v. Farley, 512 U.S. 339, 354 (1994)). A district court must order an evidentiary hearing in a federal habeas case if a defendant’s § 2255 allegations raise an issue of material fact. United States v. Biberfeld, 957 F.2d 98, 102 (3d Cir. 1992). But, if there is “no legally cognizable claim or the factual matters raised by the motion may be susceptible of resolution through the district judge’s review of the motion and records in the case,” the motion may be decided without a hearing. United States v. Costanzo, 625 F.2d 465, 470 (3d Cir. 1980); see also United States v. Tolliver, 800 F.3d 138, 140-41 (3d Cir. 2015). If a hearing is not held, the district judge must accept the defendant’s allegations as true “unless they

are clearly frivolous on the basis of the existing record.” Gov’t of Virgin Islands v. Bradshaw, 726 F.2d 115, 117 (3d Cir. 1984). Similarly, “vague and conclusory allegations contained in a § 2255 petition may be disposed of without further investigation by the District Court.” United States v. Thomas, 221 F.3d 430, 437 (3d Cir. 2000). Under the Sixth Amendment to the United States Constitution, a defendant has the right to effective assistance of counsel. A defendant relying on an allegation of ineffective assistance of counsel to support their request for relief under 28 U.S.C. § 2255 bears the burden of establishing that counsel’s performance was deficient. Burt v. Titlow, 571 U.S. 12, 23 (2013). “[T]he absence of evidence cannot overcome the ‘strong presumption that counsel’s conduct [fell] within the wide range of reasonable professional assistance.’” Id. (quoting Strickland v. Washington, 466 U.S. 668, 690 (1984)). To prove ineffective assistance of counsel, a movant must establish: [first,] that counsel’s performance was deficient. This requires showing that counsel made errors so serious that counsel was not functioning as the “counsel” guaranteed the defendant by the Sixth Amendment. Second, the defendant must show that the deficient performance prejudiced the defense. This requires showing that counsel’s errors were so serious as to deprive the defendant of a fair trial, a trial whose result is reliable.

Travillion, 759 F.3d 289 (quoting Strickland, 466 U.S. at 687). If it is easier to dispose of an ineffective assistance claim on the ground that the petitioner has not shown sufficient prejudice, a court may begin with that prong of the Strickland test. Id. The Third Circuit has explained: As the Supreme Court has stated, “the Constitution guarantees criminal defendants only a fair trial and a competent attorney.

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United States of America v. Kevin Carney, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-of-america-v-kevin-carney-pawd-2026.