United States v. Cohn

CourtCourt of Appeals for the Tenth Circuit
DecidedSeptember 4, 2024
Docket24-5037
StatusUnpublished

This text of United States v. Cohn (United States v. Cohn) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Cohn, (10th Cir. 2024).

Opinion

Appellate Case: 24-5037 Document: 010111104983 Date Filed: 09/04/2024 Page: 1 FILED United States Court of Appeals UNITED STATES COURT OF APPEALS Tenth Circuit

FOR THE TENTH CIRCUIT September 4, 2024 _________________________________ Christopher M. Wolpert Clerk of Court UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v. No. 24-5037 (D.C. No. 4:22-CR-00298-SEH-1) MIKAILI DIWANI COHN, (N.D. Okla.) a/k/a ebromanee,

Defendant - Appellant. _________________________________

ORDER AND JUDGMENT* _________________________________

Before HOLMES, Chief Judge, HARTZ and TYMKOVICH, Circuit Judges. _________________________________

The government has filed a motion to enforce the appeal waiver in Mikaili

Diwani Cohn’s plea agreement under United States v. Hahn, 359 F.3d 1315 (10th Cir.

2004) (en banc). Exercising jurisdiction under 28 U.S.C. § 1291, we grant the

motion and dismiss the appeal.

Background

Mr. Cohn pled guilty to receipt and distribution of child pornography (Count

One), possession of child pornography (Count Two), and failure to register as a sex

offender (Count Three). As Mr. Cohn acknowledged in his plea agreement, he faced

* This order and judgment is not binding precedent, except under the doctrines of law of the case, res judicata, and collateral estoppel. It may be cited, however, for its persuasive value consistent with Fed. R. App. P. 32.1 and 10th Cir. R. 32.1. Appellate Case: 24-5037 Document: 010111104983 Date Filed: 09/04/2024 Page: 2

no less than 15 years and up to 40 years in prison on Count One; no less than 10

years and up to 20 years in prison on Count Two; and a maximum sentence of 10

years in prison on Count Three. The government agreed to stipulate to a total

sentence of 15 years in prison on concurrent sentences, followed by lifetime

supervised release. In exchange, Mr. Cohn agreed to waive his right to appeal his

conviction and sentence, unless his sentence exceeded the statutory maximum. Mr.

Cohn received the agreed-upon sentence.

Despite the appeal waiver in his plea agreement, Mr. Cohn filed this appeal.

The government moved to enforce the appeal waiver under Hahn. Mr. Cohn’s

counsel filed a response with an Anders brief and a motion for leave to withdraw.

See Anders v. California, 386 U.S. 738, 744 (1967) (defense counsel may “request

permission to withdraw” when counsel conscientiously examines a case and

determines that an appeal would be “wholly frivolous”). Counsel stated his belief

that “there is no viable appeal,” but noted one “close question” and a potential

ineffective-assistance-of-counsel argument—presumably to satisfy his obligation

under Anders to “refer[] to anything in the record that might arguably support the

appeal,” id. at 744. See Counseled Resp. at 5.

The potential “close question” identified by counsel is whether the plea

colloquy for Count Two was insufficient because it failed to establish Mr. Cohn was

aware at the time of the crime—as opposed to at the time of the plea hearing—that

the child pornography he possessed included images of children who were

prepubescent or under 12 years of age, so as to establish a knowing violation of the

2 Appellate Case: 24-5037 Document: 010111104983 Date Filed: 09/04/2024 Page: 3

statute. But after identifying this question, counsel stated that Mr. Cohn waived any

claim that his plea agreement was void by failing to object to the presentence report,

which contained much more detailed information about the contents of the images,

including the ages and physical development of the children in them. Counsel also

explained why the claim would not survive plain error review and why any error was

both harmless and cured at sentencing.

The potential ineffective-assistance-of-counsel argument is based on the sparse

factual basis in the plea agreement, which “simply stated [Mr. Cohn] possessed ‘child

pornography,’ without describing the reason for use of such a conclusory term” or

establishing that Mr. Cohn “personally knew” the videos contained images of “actual

minors engaged in sexually explicit conduct, much less that some of the minors were

prepubescent and under 12 years of age,” id.

Consistent with the procedure outlined in Anders, the court allowed Mr. Cohn

to file a pro se response to show why the appeal waiver should not be enforced. He

responded, arguing that: (1) he received ineffective assistance of counsel because his

appointed counsel refused to dispute falsified testimony and illegally seized evidence

and manipulated his decision-making; (2) his probation officer conspired with his

girlfriend to create a false narrative to have him arrested; (3) the police illegally

seized evidence from his girlfriend’s home, and his appointed counsel was ineffective

because he disregarded that illegal seizure; and (4) the detention environment is not

3 Appellate Case: 24-5037 Document: 010111104983 Date Filed: 09/04/2024 Page: 4

conducive to mounting a legal defense with an ineffective attorney.1 Mr. Cohn did

not mention, let alone bolster, either of the potential arguments that his counsel

identified in his response and Anders brief.

Discussion

The government’s motion to enforce the appeal waiver requires us to

determine: “(1) whether the disputed appeal falls within the scope of the waiver of

appellate rights; (2) whether the defendant knowingly and voluntarily waived his

appellate rights; and (3) whether enforcing the waiver would result in a miscarriage

of justice.” Hahn, 359 F.3d at 1325. A miscarriage of justice occurs “where the

district court relied on an impermissible factor such as race, where ineffective

assistance of counsel in connection with the negotiation of the waiver renders the

waiver invalid, where the sentence exceeds the statutory maximum, or where the

waiver is otherwise unlawful.” Id. at 1327 (bracketed numbers and internal quotation

marks omitted). For a waiver to be “otherwise unlawful,” the district court must have

made an error that seriously affected the fairness, integrity, or public reputation of

judicial proceedings. Id.

Mr. Cohn does not address the Hahn factors in his pro se response. But our

independent review confirms all three factors support upholding the appeal waiver in

this case.

1 We consider Mr. Cohn’s response only as a response to the government’s motion to enforce the appeal waiver. We do not consider any embedded requests for relief from his sentence or probation conditions. 4 Appellate Case: 24-5037 Document: 010111104983 Date Filed: 09/04/2024 Page: 5

First, Mr. Cohn’s appeal of his conviction and sentence is within the scope of

his appeal waiver. As explained above, he waived his right to appeal his conviction

and sentence unless his sentence exceeded the statutory maximum. It did not.

Second, Mr. Cohn has not satisfied his burden of showing that he did not

knowingly and voluntarily enter into his plea agreement. See id. at 1329 (imposing

the burden on the defendant). It is clear from both the plea agreement and the

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Related

Anders v. California
386 U.S. 738 (Supreme Court, 1967)
United States v. Hahn
359 F.3d 1315 (Tenth Circuit, 2004)
United States v. Porter
405 F.3d 1136 (Tenth Circuit, 2005)

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United States v. Cohn, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-cohn-ca10-2024.