United States of America v. Linnell Richmond, Jr.

CourtDistrict Court, E.D. Tennessee
DecidedJuly 6, 2026
Docket3:16-cv-00307
StatusUnknown

This text of United States of America v. Linnell Richmond, Jr. (United States of America v. Linnell Richmond, Jr.) is published on Counsel Stack Legal Research, covering District Court, E.D. Tennessee 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. Linnell Richmond, Jr., (E.D. Tenn. 2026).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TENNESSEE

UNITED STATES OF AMERICA, ) ) Plaintiff, ) ) v. ) No.: 3:95-CR-126-TAV-DCP ) 3:16-CV-307-TAV-DCP LINNELL RICHMOND, JR., ) ) Defendant. )

MEMORANDUM OPINION AND ORDER

This action is before the Court on defendant’s pro se “Motion Rule 60(b) to Correct an [sic] Defective Proceeding/Ruling” [Doc. 366; Case No. 3:16-cv-307, Doc. 44], supplemented by counsel [Docs. 370, 378, 379, 380], and defendant’s “Renewed Second-in-Time 2255 Motion” [Doc. 367].1 The government has responded [Doc. 376], and defendant replied [Doc. 377]. Also pending before the Court are defendant’s “Motion to Independently Vacate Mr. Richmond’s 924(c)(1)(A) and also 924(c)(B)(ii)” [Doc. 382] and Motion for Leave to Appeal In Forma Pauperis (“IFP”) [Case No. 3:16-cv-307, Doc. 57]. This matter is now ripe for resolution. For the reasons discussed below, defendant’s Rule 60(b) motion [Doc. 366; Case No. 3:16-cv-307, Doc. 44] is GRANTED. Defendant’s conviction as to Count 2 is VACATED, and this matter will be set for resentencing.

1 Citations to the record refer to the criminal docket, Case No. 3:95-cr-126, unless otherwise noted. Defendant’s Motion for Leave to Appeal IFP [Case No. 3:16-cv-307, Doc. 57] is DENIED. Further, in light of the ruling on the Rule 60(b) motion, defendant’s “Renewed Second-in-Time 2255 Motion” [Doc. 367] and “Motion to Independently Vacate Mr.

Richmond’s 924(c)(1)(A) and also 924(c)(B)(ii)” [Doc. 382] are DENIED as moot to the extent that they seek vacatur of his conviction on Count 2. However, regarding defendant’s requests to vacate Count Four, the Court finds that defendant’s motions [Docs. 367, 382] are unauthorized second or successive motions under § 2255, and it will TRANSFER the motions to the Sixth Circuit Court of Appeals.

I. Background In 1996, a jury convicted defendant of conspiracy to commit Hobbs Act Robbery, in violation of 18 U.S.C. § 371 (Count 1); aiding and abetting a Hobbs Act Robbery, in violation of 18 U.S.C. §§ 1951 and 2 (Count 3); two counts of aiding and abetting the use of a firearm during and in relation to a crime of violence, in violation of 18 U.S.C. § 924(c)

and 2 (Counts 2 & 4), and aiding and abetting possession of a machine gun, in violation of 18 U.S.C. § 922(o) and 2 (Count 5) [Doc. 233]. See also United States v. Richmond, 129 F.3d 1255 (table), Nos. 96-5879, 96-5880, 96-5886, 1997 WL 720469, at *1 (6th Cir. Nov. 12, 1997) (per curiam). As is relevant to the issue at hand, the crime of violence for purposes of the § 924(c) offense charged in Count 2 was the conspiracy to commit Hobbs

Act Robbery, charged in Count 1, while the crime of violence for purposes of the § 924(c) offense charged in Count 4 was the substantive Hobbs Act Robbery, charged in Count 3 [Doc. 1]. Defendant was sentenced to an aggregate term of 411 months’ imprisonment 2 [Doc. 233]. The Sixth Circuit affirmed defendant’s convictions and sentence, and the Supreme Court denied certiorari. See Richmond, 1997 WL 720469; Richmond v. United States, 523 U.S. 1032 (1998).

In June 2016, Defendant filed a pro se motion to vacate, set aside, or correct sentence under 28 U.S.C. § 2255, in light of Johnson v. United States, 576 U.S. 591 (2015), which invalidated the residual clause of the Armed Career Criminal Act [Doc. 271; Case No. 3:16-cv-307, Doc. 1]. In that motion, defendant argued that the residual clause in 18 U.S.C. § 924(c) was likewise unconstitutionally vague and Hobbs Act Robbery was not a

“crime of violence” under the § 924(c)(3)’s force clause because it could be violated without the use of violent physical force [Id. at 4]. While the motion was pending, the Supreme Court granted certiorari in United States v. Davis, 588 U.S. 445 (2019) to decide whether the residual clause in § 924(c) is unconstitutionally vague. Before the Supreme Court decided Davis, defendant filed a pro

se motion to amend his § 2255 motion, specifically arguing that conspiracy to commit Hobbs Act Robbery, which is the predicate conviction underlying his § 924(c) conviction on Count 2, is not a crime of violence under § 924(c)’s force clause [Case No. 3:16-cv- 307, Doc. 18]. On May 28, 2019, this Court granted the motion to amend but denied and dismissed

defendant’s § 2255 motion, concluding that defendant’s § 924(c) convictions remained valid, even in light of Johnson, because Hobbs Act Robbery qualifies as a crime of violence under § 924(c)’s force clause [Docs. 295, 296; Case No. 3:16-cv-307, Docs. 19, 20]. 3 However, the Court did not address any distinction between the substantive Hobbs Act robbery predicate for Count 4 and the conspiracy Hobbs Act robbery predicate for Count 2 [See id.]. The Court denied a certificate of appealability (“COA”) [Id.].

On June 24, 2019, the Supreme Court decided Davis, which invalidated the residual clause of § 924(c). United States v. Davis, 588 U.S. 445 (2019). Defendant then filed a pro se motion for reconsideration on July 1, 2019, arguing that conspiracy to commit Hobbs Act Robbery does not qualify as a “crime of violence” after Davis [Case No. 3:16- cv-307, Docs. 21, 24, 25]. This Court denied the motion, again explaining that defendant’s

Hobbs Act Robbery convictions were crimes of violence under § 924(c)’s force clause [Doc. 299; Case No. 3:16-cv-307, Doc. 26]. But again, the Court did not distinguish between the substantive and conspiracy Hobbs Act Robbery predicates that underlie Counts 4 and 2, respectively [See id.]. The Sixth Circuit subsequently denied a COA [Case No. 3:16-cv-307, Doc. 28]. The Sixth Circuit agreed that “Davis has no effect on

[defendant’s] § 924(c) convictions because the Hobbs Act robbery offense that underlies those convictions qualifies as a crime of violence under § 924(c)(3)(A), which is the use-of-force, rather than the residual, clause of § 924(c)(3)” [Id. at 4]. The Sixth Circuit did not acknowledge or distinguish the substantive and conspiracy Hobbs Act Robbery convictions underlying Counts 4 and 2, respectively [See id.].

Thereafter, defendant moved the Sixth Circuit for leave to file a second or successive § 2255 motion, pursuant to 28 U.S.C. §§ 2244(b)(3)(C) and 2255(h), based on the rule announced in Davis, again contending that, in light of that new rule, conspiracy to 4 commit Hobbs Act Robbery was no longer a crime of violence for § 924(c) purposes [Case No. 3:16-cv-307, Doc. 27, pp. 1, 5]. The Sixth Circuit denied this request because the rule announced in Davis was previously available to defendant, and he expressly relied on it in

a motion for reconsideration [Case No. 3:16-cv-307, Doc. 29, p. 4].

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United States of America v. Linnell Richmond, Jr., Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-of-america-v-linnell-richmond-jr-tned-2026.