United States v. Bonner

CourtDistrict Court, N.D. Illinois
DecidedDecember 18, 2024
Docket1:24-cv-05777
StatusUnknown

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

Bluebook
United States v. Bonner, (N.D. Ill. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

CORDARO BONNER, ) ) Petitioner, ) ) Case No. 24 CV 05777 v. ) ) Judge Sharon Johnson Coleman ) UNITED STATES OF AMERICA, ) ) Respondent. )

MEMORANDUM OPINION AND ORDER

Pro se petitioner Cordaro Bonner filed the present motion to vacate, set aside, or correct his sentence pursuant to 28 U.S.C. § 2255. For the reasons stated below, the Court denies Bonner’s motion and declines to certify any issues for appeal. 28 U.S.C. § 2253(c)(2). Background On August 7, 2019, Bonner was charged in a two-count indictment with unlawful possession of a firearm by a felon, in violation of 18 U.S.C. § 922(g)(1), and possession of a controlled substance, namely marijuana, in violation of 21 U.S.C. § 844(a). United States v. Bonner, No. 19 CR 00634-1 (N.D. Ill). The indictment arose from Bonner’s arrest on February 25, 2019, after Bonner, while knowingly in possession of a loaded semi-automatic pistol, fled from police officers through a residential area and threw the firearm onto the balcony of a residence in an attempt to discard it. On January 19, 2022, Bonner voluntarily pleaded guilty to the first count of the indictment pursuant to a plea agreement with the Government. On April 14, 2022, this Court entered judgment against and sentenced Bonner to 62 months of incarceration, with credit for time already served, as well as a term of three years of supervised release. Bonner filed a motion to modify his sentence pursuant to 18 U.S.C. § 3582(c)(2) on February 21, 2024. Thereafter, Bonner, who is currently incarcerated, filed the instant motion to vacate, set aside, or correct his sentence under 28 U.S.C. § 2255. The handwritten date on the signature page of the motion displays June 25, 2024. The file stamp indicates that the Clerk’s Office for the U.S. District Court for the Northern District of Illinois received the motion on July 2, 2024. Legal Standard To obtain relief under 28 U.S.C. § 2255, a petitioner must show that his “sentence was imposed

in violation of the Constitution or laws of the United States, the court lacked jurisdiction, the sentence was greater than the maximum authorized by law, or it is otherwise subject to collateral attack.” A petitioner must bring a § 2255 motion within one year 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). For purposes of calculating the deadline under the relevant limitations period, a pro se prisoner’s paper is deemed “filed” at the moment of delivery to prison officials for forwarding to the district court. See Houston v. Lack, 487 U.S. 266, 275-76 (1988) (adopting “mailbox rule”). Discussion Bonner brings this motion arguing that his conviction pursuant to 18 U.S.C. § 922(g)(1) is invalid after the Supreme Court’s opinion in New York State Rifle & Pistol Ass’n v. Bruen, 597 U.S. 1 (2022). Specifically, Bonner (1) raises a facial and as-applied constitutional challenge to his conviction under the Second Amendment of the U.S. Constitution, and (2) claims that he received ineffective assistance of counsel because his trial counsel failed to research, advise Bonner about, or challenge Section 922(g)(1) under the Second Amendment. The Government argues that the Court should dismiss Bonner’s motion because it is untimely, and, separately, because Bonner has not demonstrated actual innocence. We agree. I. Bonner’s § 2255 Motion is Untimely Bonner’s motion is untimely. Bonner had one year to file his § 2255 motion. 28 U.S.C. § 2255(f). The one-year statute of limitations commenced upon the latest of: (1) the date on which judgment of conviction became final; (2) the removal of a government-created unconstitutional

impediment preventing a timely filing; (3) the date on which a 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 could have been discovered through due diligence. Id. Because Bonner claims neither the existence of any unconstitutional government-created impediment that prevented him from filing this motion nor that he was unaware of relevant facts, the Court finds that § 2255(f)(2) and (4) are inapplicable for purposes of determining the timeliness of Bronner’s motion. The Court thus turns its analysis to § 2255(f)(1) and (3).

Bonner’s petition is untimely under § 2255(f)(1). Under § 2255(f)(1), a petitioner must bring a § 2255 motion within one year of the date on which the judgment of conviction becomes final. Where a defendant does not exercise his right to direct appeal, a judgment of conviction becomes

final when the deadline to appeal the sentence expires. See Clarke v. United States, 703 F.3d 1098, 1100 (7th Cir. 2013). This Court entered judgment against Bonner on April 14, 2022. Bonner had 14 days to appeal the judgment to the Seventh Circuit, see Fed. R. App. P. 4(b), but did not invoke this right. The judgment therefore became final upon expiration of Bonner’s right to appeal—14 days after the Court entered judgment—on April 28, 2022. Bonner had until April 28, 2023, one year after which the judgment of conviction became final, to file a § 2255 motion. Under the prison mailbox rule of Houston v. Lack, 487 U.S. 266 (1988), Bonner “filed” this motion on June 25, 2024, the date that appears on the signature page of the motion. The Court deems this date a sufficient proxy for the date that Bonner delivered the motion to prison officials. See Houston, 487 U.S. at 275-76. In light of Bonner’s April 28, 2023 deadline, Bonner’s motion is untimely

by nearly 14 months. The Government’s incorrect date calculation is of no consequence, as the Court’s use of the earlier date still renders Bonner’s motion untimely.

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Related

Houston v. Lack
487 U.S. 266 (Supreme Court, 1988)
Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
Lorna Clarke v. United States
703 F.3d 1098 (Seventh Circuit, 2013)
McQuiggin v. Perkins
133 S. Ct. 1924 (Supreme Court, 2013)
Morales v. Bezy
499 F.3d 668 (Seventh Circuit, 2007)
Kunta Gray v. Dushan Zatecky
865 F.3d 909 (Seventh Circuit, 2017)

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Bluebook (online)
United States v. Bonner, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-bonner-ilnd-2024.