United States v. Davis

CourtDistrict Court, District of Columbia
DecidedSeptember 20, 2024
DocketCriminal No. 2018-0026
StatusPublished

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

Bluebook
United States v. Davis, (D.D.C. 2024).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA

v. Criminal Action No. 18-26 (TJK) RODNEY DAVIS,

Defendant.

MEMORANDUM ORDER

Defendant Rodney Davis pleaded guilty to one count of Travel with Intent to Engage in

Illicit Sexual Conduct, in violation of 18 U.S.C. § 2423(b), and was sentenced. Now proceeding

pro se, Davis moves to vacate, set aside, or correct that sentence under 28 U.S.C. § 2255, based

largely on ineffective assistance of counsel in connection with the plea and sentencing. For the

reasons explained below, the Court will deny the motion.

I. Background

In May 2018, Davis pleaded guilty to one count of Travel with Intent to Engage in Illicit

Sexual Conduct, in violation 18 U.S.C. § 2423(b). ECF Nos. 14, 15. Davis admitted to traveling

across state lines to engage in a sexual act with what turned out to be a fictious eight-year-old girl,

after engaging in conversations about doing so with an undercover police officer. ECF No. 15. In

a written plea agreement, Davis agreed to a standard waiver of appeal rights, as well as to “waive[]

any right to challenge the conviction entered or sentence imposed . . . in any collateral attack,

including . . . a motion brought under 28 U.S.C. § 2255 . . . except to the extent such a motion is

based on newly discovered evidence or on a claim that your client received ineffective assistance

of counsel.” ECF No. 14 at 6–7. In August 2019, the Court sentenced Davis to 108 months of

incarceration followed by ten years of supervised release. ECF No. 29. That sentence of incar- ceration represented the bottom of the applicable sentencing guidelines range, after the Court ap-

plied a four-point “minor victim” specific offense characteristic because “the victim had not at-

tained the age of twelve years.” U.S.S.G. § 2A3.1(b)(2)(A). The parties agreed to that enhance-

ment both in the plea agreement, at the change-of-plea hearing, and at sentencing. See ECF No.

14 at 2; ECF No. 37 at 9–10.

Davis appealed, alleging ineffective assistance of counsel, and in July 2022, the Circuit

affirmed both the conviction and sentence. United States v. Davis, 45 F.4th 73 (D.C. Cir. 2022).

Specifically, it upheld the Court’s application of the minor victim enhancement, holding that it

applied even though the victim was fictitious, and thus counsel’s failure to raise what would have

been a meritless challenge was not constitutionally deficient. Id. at 77–80. The Circuit also found

that Davis’s appeal waiver was made knowingly, intelligently, and voluntarily, and so it did not

reach the rest of Davis’s claims that the Court made substantive and procedural errors during sen-

tencing. Id. at 80–81. 1

A year later, Davis, proceeding pro se, moved to vacate, set aside, or correct the sentence

under 28 U.S.C. § 2255, again largely relying on claims of ineffective assistance of counsel. ECF

No. 48. The Government opposes. ECF No. 52. Davis also moved to compel disclosure of all

records related to the case under the control of the District of Columbia Federal Public Defender’s

Office, ECF No. 55, as well as to appoint counsel, ECF No. 56.

1 These claims were that the Court erred at sentencing “by failing to announce the standard conditions of Davis’ supervised release; inadequately factoring Davis’ gender identity into the sentence; and rejecting evidence of sentencing disparities between Davis and similarly situated defendants.” Davis, 45 F.4th at 80.

2 II. Legal Standard

A motion under § 2255 allows federal prisoners to collaterally attack an otherwise final

sentence if the sentence was (1) “imposed in violation of the Constitution or laws of the United

States,” (2) “the court was without jurisdiction to impose [the] sentence,” (3) “the sentence was in

excess of the maximum authorized by law,” or (4) the sentence “is otherwise subject to collateral

attack.” 28 U.S.C. § 2255(a). “The petitioner bears the burden of proof under § 2255 and must

demonstrate her right to relief by a preponderance of the evidence.” United States v. Ashton, 961

F. Supp. 2d 7, 11 (D.D.C. 2013); United States v. Simpson, 475 F.2d 934, 935 (D.C. Cir. 1973).

“Relief under § 2255 is an extraordinary remedy in light of society’s legitimate interest in the

finality of judgments.” United States v. Moore, 75 F. Supp. 3d 568, 571 (D.D.C. 2014). As a

result, it is typically only granted if “the challenged sentence resulted from ‘a fundamental defect

which inherently results in a complete miscarriage of justice,’ or ‘an omission inconsistent with

the rudimentary demands of fair procedure.’” United States v. Pollard, 959 F.2d 1011, 1020 (D.C.

Cir. 1992) (citation omitted).

Thus, a motion to vacate “under § 2255 is neither a second chance at appeal nor is it a

substitute for direct appeal.” Ashton, 961 F. Supp. 2d at 11. That is, a defendant “cannot raise

collaterally any issue litigated and adjudicated on direct review, absent exceptional circum-

stances.” Moore, 75 F. Supp. 3d at 572; see also Ashton, 961 F. Supp. 2d at 11. Similarly, once

“a defendant has procedurally defaulted a claim by failing to raise it on direct review, the claim

may be raised in habeas only if the defendant can first demonstrate either ‘cause’ and actual ‘prej-

udice’” or “actual innocence.” Bousley v. United States, 523 U.S. 614, 622 (1998). Cause for

default exists where “some ‘objective factor external to the defense’ impeded efforts to raise an

issue in trial or on direct appeal.” Moore, 75 F. Supp. 3d at 572 (quoting Murray v. Carrier, 477

U.S. 478, 488 (1986)). And to show “actual prejudice,” a petitioner “must at least demonstrate

3 that ‘there is a reasonable probability that, but for [the errors], the result of the proceeding would

have been different.’” United States v. Pettigrew, 346 F.3d 1139, 1144 (D.C. Cir. 2003) (citation

omitted). But “[w]here a petitioner raises claims of ineffective assistance of counsel in a § 2255

motion, he need not show ‘cause and prejudice’ for not having raised such claims on direct appeal,

as these claims may properly be raised for the first time in a § 2255 motion.” United States v.

Cook, 130 F. Supp. 2d 43, 45 (D.D.C. 2000), aff’d, 22 F. App’x 3 (D.C. Cir. 2001) (citation omit-

ted).

III. Analysis

Because Davis proceeds pro se, the Court construes this motion expansively, to challenge

the lawfulness of Davis’s plea, waiver of collateral attack rights, and sentence, as well as to assert

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