United States v. Reed

39 F.4th 1285
CourtCourt of Appeals for the Tenth Circuit
DecidedJuly 7, 2022
Docket21-2073
StatusPublished
Cited by17 cases

This text of 39 F.4th 1285 (United States v. Reed) 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. Reed, 39 F.4th 1285 (10th Cir. 2022).

Opinion

Appellate Case: 21-2073 Document: 010110706733 Date Filed: 07/07/2022 Page: 1 FILED United States Court of Appeals PUBLISH Tenth Circuit

UNITED STATES COURT OF APPEALS July 7, 2022

Christopher M. Wolpert FOR THE TENTH CIRCUIT Clerk of Court _________________________________

UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v. No. 21-2073

JASON REED,

Defendant - Appellant. _________________________________

Appeal from the United States District Court for the District of New Mexico (D.C. No. 1:18-CR-01576-KWR-1) _________________________________

Todd B. Hotchkiss, Albuquerque, New Mexico, for Defendant-Appellant.

Emil J. Kiehne, Assistant United States Attorney (Fred J. Federici, United States Attorney, with him on the brief), Albuquerque, New Mexico, for Plaintiff-Appellee. _________________________________

Before TYMKOVICH, Chief Judge, BALDOCK, and ROSSMAN, Circuit Judges. _________________________________

BALDOCK, Circuit Judge. _________________________________

Defendant Jason Reed pleaded guilty to being a felon in possession of a firearm.

At sentencing, the district court concluded Defendant’s previous convictions for drug

distribution qualified him for enhanced criminal penalties under the Armed Career

Criminal Act (ACCA). That statute mandates a 15-year minimum sentence for Appellate Case: 21-2073 Document: 010110706733 Date Filed: 07/07/2022 Page: 2

unlawful firearm possession when the offender has three or more previous convictions

for serious drug offenses “committed on occasions different from one another.”

18 U.S.C. § 924(e)(1). The district court applied the ACCA enhancement and

sentenced Defendant to 15 years’ imprisonment—the mandatory minimum. Defendant

makes three challenges on appeal. First, he claims his guilty plea was unknowing or

involuntary because his counsel erroneously advised him that the ACCA was unlikely

to apply. Second, he argues the district court lacked the power to decide whether his

prior federal drug-trafficking convictions qualified as ACCA predicate felonies. Third,

he alleges he was given insufficient notice that the ACCA might apply to him.

Exercising jurisdiction under 28 U.S.C. § 1291 and 18 U.S.C. § 3742(a), we affirm.

I.

Defendant was previously convicted of several felonies. In 2004, he was

convicted in federal court of four felonies: three counts of distributing a mixture

containing cocaine base and one count of disposing a firearm to a convicted felon.

Even though the four convictions were contained in a single judgment, each conviction

was—according to the judgment—concluded on a different date. A year later,

Defendant was convicted in state court of trafficking cocaine.

The present appeal arises out of Defendant’s more recent criminal activity. In

September 2017, Defendant knowingly brought a handgun and several rounds of

ammunition to an apartment in Farmington, New Mexico. A grand jury indicted

Defendant for being a felon in possession of a firearm and ammunition. 18 U.S.C.

§ 922(g)(1). Initially, Defendant wanted to go to trial. But it soon became apparent

2 Appellate Case: 21-2073 Document: 010110706733 Date Filed: 07/07/2022 Page: 3

that he was unlikely to obtain an acquittal: a laboratory found Defendant’s DNA on the

handgun and Defendant’s initial trial counsel (referred to throughout as “trial counsel”)

was unable to locate any witness to support Defendant’s version of events.

The Government offered Defendant a plea agreement. Among other things, the

agreement stated that the maximum prison sentence Defendant could receive was

10 years, unless the district court determined he was an armed career criminal under

the ACCA, in which case his minimum prison sentence would be 15 years and his

maximum sentence would be life. The agreement also informed Defendant that

“regardless of any of the parties’ recommendations, the Defendant’s final sentence is

solely within the discretion of the Court.” Trial counsel advised Defendant about

whether he should accept the Government’s plea agreement. Given Defendant’s prior

convictions, trial counsel worried Defendant might qualify for a sentencing

enhancement under the ACCA, and he discussed that issue with Defendant. But trial

counsel’s advice was flawed. As discussed in further detail below, trial counsel

mistakenly believed Defendant did not have the requisite number of felonies for an

ACCA enhancement, and trial counsel advised Defendant based on this erroneous

belief. Trial counsel, however, was careful not to promise Defendant that the ACCA

would not apply. Defendant entered the plea agreement.

At his change-of-plea hearing, Defendant was once again reminded of the

possibility of an ACCA enhancement and the consequences associated with pleading

guilty. Echoing the plea agreement, the prosecutor reminded Defendant that he faced

a maximum of 10 years’ imprisonment unless the district court determined that he was

3 Appellate Case: 21-2073 Document: 010110706733 Date Filed: 07/07/2022 Page: 4

an armed career criminal, in which case he would face a mandatory minimum term of

15 years’ imprisonment and a maximum sentence of life imprisonment. Defendant

acknowledged that he understood the charge and the maximum penalties that go along

with it. He also acknowledged that, in the event he received a sentence he did not

expect, he would be unable to withdraw his guilty plea. Additionally, Defendant

agreed that the factual basis of his offense, as set forth in the plea agreement, was true

and accurate, and that he was pleading guilty because he was in fact guilty. He also

indicated that no one had made any promises (other than those in the plea agreement)

to encourage him to plead guilty. Defendant then pleaded guilty.

The United States Probation Office issued Defendant’s Presentence

Investigation Report (PSR) on November 26, 2019. Based on Defendant’s previous

convictions—specifically, Defendant’s three federal drug-trafficking convictions—the

PSR concluded Defendant was subject to an enhanced sentence under the ACCA. See

18 U.S.C. § 924(e)(1) (imposing a 15-year mandatory minimum sentence when an

18 U.S.C. § 922(g) defendant has three previous convictions for serious drug offenses

committed on “occasions different from one another”). Because the PSR’s ACCA

finding directly contradicted trial counsel’s advice, Defendant obtained new counsel

and moved to withdraw his guilty plea. He argued that his guilty plea was unknowing

or involuntary because trial counsel’s erroneous advice constituted ineffective

assistance of counsel.

The district court held an evidentiary hearing on the motion. Trial counsel

testified at the hearing, explaining how he reached the conclusion that Defendant was

4 Appellate Case: 21-2073 Document: 010110706733 Date Filed: 07/07/2022 Page: 5

unlikely to receive an ACCA enhancement. According to his testimony, trial counsel

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39 F.4th 1285, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-reed-ca10-2022.