W. LeNeve v. United States

CourtCourt of Appeals for the Eleventh Circuit
DecidedNovember 5, 2025
Docket25-11992
StatusUnpublished

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

Bluebook
W. LeNeve v. United States, (11th Cir. 2025).

Opinion

USCA11 Case: 25-11992 Document: 23-1 Date Filed: 11/05/2025 Page: 1 of 7

NOT FOR PUBLICATION

In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 25-11992 Non-Argument Calendar ____________________

W. LAWRENCE LENEVE, a.k.a. Larry LeNeve, Plaintiff-Appellant, versus

UNITED STATES OF AMERICA, Defendant-Appellee. ____________________ Appeal from the United States District Court for the Southern District of Florida D.C. Docket No. 9:25-cv-80498-DMM ____________________

Before NEWSOM, BRANCH, and BRASHER, Circuit Judges. PER CURIAM: William LeNeve appeals the district court’s order denying his pro se petition for a writ of error coram nobis. He argues that USCA11 Case: 25-11992 Document: 23-1 Date Filed: 11/05/2025 Page: 2 of 7

2 Opinion of the Court 25-11992

the district court erred in summarily denying his petition because “no verbatim record or transcript” of his 2006 plea colloquy exists, which he maintains is a jurisdictional defect that requires vacatur of the judgment. He maintains that he demonstrated sound reasons for the delay in filing the petition because he did not learn of the lack of a record of the plea colloquy until completion of his sentence and because his trial counsel was ineffective. 1 After review, we affirm. I. Background In 2006, LeNeve pleaded guilty to bankruptcy fraud pursuant to a written plea agreement. He was sentenced to 60 months’ imprisonment followed by three years of supervised release. LeNeve did not file a direct appeal, and he completed his sentence in November 2013. Almost 12 years later, he filed the underlying petition for a writ of error coram nobis. He argued that the district court had “accepted [his] plea and did not hold any semblance of the mandatory elements” for a valid plea under Federal Rule of Criminal Procedure 11, including failing to hold a change-of-plea

1 LeNeve also alleges that the district court erred in recharacterizing his coram

nobis petition as a motion to vacate sentence under 28 U.S.C. § 2255 because he is no longer in custody and thus relief is not available to him under § 2255. However, contrary to LeNeve’s contention, the record establishes that the district court did not recharacterize his petition as a § 2255 motion and properly treated it as a petition for writ of error coram nobis. Accordingly, we do not address this issue further. USCA11 Case: 25-11992 Document: 23-1 Date Filed: 11/05/2025 Page: 3 of 7

25-11992 Opinion of the Court 3

hearing2 or to create a record of the hearing. He further asserted that his trial counsel was ineffective for failing to ensure that Rule 11 was followed and for purportedly misadvising LeNeve that he had waived his right to appeal. 3 He asserted that, because Rule 11 was not followed, the district court lacked jurisdiction, and the judgment must be vacated. The district court summarily denied the petition, concluding that LeNeve was not entitled to relief because he failed to present sound reasons for not seeking relief sooner. The district court explained that LeNeve failed to allege when the alleged errors became known to him, and noted that he could have challenged

2 Despite LeNeve’s contentions that no plea hearing was held, we note that

the criminal docket contains a minute entry for a change-of-plea hearing on December 14, 2006. 3 We note that LeNeve’s plea agreement contained a sentence-appeal waiver

in which he waive[d] all rights conferred by [18 U.S.C. §] 3742 to appeal any sentence imposed, including any restitution order, or to appeal the manner in which the sentence was imposed, unless the sentence exceed[ed] the maximum permitted by statute or [was] the result of an upward departure from the guideline range that the Court establish[ed] at sentencing, or to file any other direct appeal of any sentence imposed.

He also waived his right to collaterally attack the conviction. However, the appeal waiver would not have barred a challenge to the validity of LeNeve’s guilty plea. See United States v. Puentes-Hurtado, 794 F.3d 1278, 1284 (11th Cir. 2015) (explaining that it is well-established that an appeal waiver does not bar a Rule 11 challenge that goes to the validity of the plea itself). USCA11 Case: 25-11992 Document: 23-1 Date Filed: 11/05/2025 Page: 4 of 7

4 Opinion of the Court 25-11992

the validity of his plea on direct appeal, and he could have raised his ineffective-assistance claim in a § 2255 motion, but chose not to do so. LeNeve filed a timely motion for reconsideration in which he reiterated the merits of his petition. The district court denied the motion, and this appeal followed. II. Discussion LeNeve argues that the district court erred in summarily dismissing his petition for a writ of error coram nobis because no record of his 2006 plea colloquy exists, which he maintains is a jurisdictional defect that renders the judgment in his case unconstitutional. He maintains that he demonstrated sound reasons for the delay in filing the petition because he did not learn of the lack of a record of the plea colloquy until completion of his sentence and because his trial counsel was ineffective for failing to ensure that the requirements of Rule 11 were followed and for advising him that he had waived his right to appeal. The All Writs Act, 28 U.S.C. § 1651(a), provides federal courts with the authority to issue writs of error coram nobis. United States v. Mills, 221 F.3d 1201, 1203 (11th Cir. 2000). “A writ of error coram nobis is a remedy available to vacate a conviction when the petitioner has served his sentence and is no longer in custody, as is required for post-conviction relief under 28 U.S.C. § 2255.” United States v. Peter, 310 F.3d 709, 712 (11th Cir. 2002). Because “the results of [a] conviction may persist,” the writ makes relief available to a petitioner who has served his sentence and is USCA11 Case: 25-11992 Document: 23-1 Date Filed: 11/05/2025 Page: 5 of 7

25-11992 Opinion of the Court 5

no longer in custody. Id. (quotations omitted). “The writ of error coram nobis is an extraordinary remedy of last resort available only in compelling circumstances where necessary to achieve justice.” Mills, 221 F.3d at 1203. “To obtain coram nobis relief, a petitioner must present sound reasons for failing to seek relief earlier.” Gonzalez v. United States, 981 F.3d 845, 851 (11th Cir. 2020) (alteration adopted) (quotations omitted). “The bar for coram nobis relief is high.” Alikhani v. United States, 200 F.3d 732, 734 (11th Cir. 2000). The writ may issue only when (1) no other avenue of relief is, or was, available, and (2) “the error involves a matter of fact of the most fundamental character which has not been put in issue or passed upon and which renders the proceeding itself irregular and invalid.” Id. (quotations omitted). We review the “district court’s denial of coram nobis relief . . . for abuse of discretion.” Peter, 310 F.3d at 711. We review the district court’s determination of whether a petitioner has presented sound reasons for failing to seek relief earlier for clear error.

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Related

Alikhani v. United States
200 F.3d 732 (Eleventh Circuit, 2000)
United States v. Michael J. Peter
310 F.3d 709 (Eleventh Circuit, 2002)
Derrick Rivers v. United States
416 F.3d 1319 (Eleventh Circuit, 2005)
United States v. Timmreck
441 U.S. 780 (Supreme Court, 1979)
United States v. Lauro Puentes-Hurtado
794 F.3d 1278 (Eleventh Circuit, 2015)
Jose Carlos Gonzales v. United States
981 F.3d 845 (Eleventh Circuit, 2020)

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