Whittenberg v. United States

CourtDistrict Court, E.D. Tennessee
DecidedJune 30, 2025
Docket3:24-cv-00273
StatusUnknown

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

Bluebook
Whittenberg v. United States, (E.D. Tenn. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TENNESSEE

GAGE WHITTENBERG, ) ) Petitioner, ) ) v. ) Nos.: 3:24-CV-273-TAV-DCP ) 3:19-CR-220-TAV-DCP-2 UNITED STATES OF AMERICA, ) ) Respondent. )

MEMORANDUM OPINION Petitioner Gage Whittenberg has filed a motion to vacate, set aside, or correct his sentence under 28 U.S.C. § 2255 [Doc. 1; Case No. 3:19-cr-220 (“Criminal Case”), Doc. 924].1 The government responded in opposition [Doc. 7]. Because, based on the record, it plainly appears that petitioner is not entitled to relief, it is not necessary to hold an evidentiary hearing,2 and petitioner’s § 2255 motion [Doc. 1; Criminal Case, Doc. 924] will be DENIED. I. Background On February 14, 2022, petitioner pled guilty to conspiracy to distribute 50 grams or more of methamphetamine, in violation of 21 U.S.C. §§ 846, 841(a)(1), 841(b)(1)(A) (Count 1), conspiracy to distribute 1 kilogram or more of heroin and 400 grams or more of

1 All docket citations refer to the civil case unless otherwise indicated. 2 An evidentiary hearing is required on a § 2255 motion unless the motion, files, and record conclusively show that the prisoner is not entitled to relief. See 28 U.S.C. § 2255(b). It is the prisoner’s ultimate burden, however, to sustain his claims by a preponderance of the evidence. See Pough v. United States, 442 F.3d 959, 964 (6th Cir. 2006). Accordingly, where “the record conclusively shows that the petitioner is entitled to no relief,” a hearing is not required. Arredondo v. United States, 178 F.3d 778, 782 (6th Cir. 1999) (citation omitted). fentanyl, in violation of 21 U.S.C. §§ 846, 841(a)(1), 841(b)(1)(A) (Count 2), conspiracy to commit money laundering, in violation of 18 U.S.C. §§ 1956(h), 1956(a)(1)(A)(i) (Count 4), and possessing and discharging a firearm in furtherance of a drug trafficking

crime, in violation of 18 U.S.C. § 924(c) (Count 10) [Criminal Case, Docs. 465, 525]. Of note, the superseding indictment listed the offenses in Counts 1 and 2, as well as another charged offense to which petitioner did not plead guilty, as the predicate drug trafficking crimes for purposes of the § 924(c) conviction in Count 10 [Criminal Case, Doc. 23]. Pursuant to Federal Rule of Criminal Procedure 11(c)(1)(C), the parties agreed that

a sentence of 255 months’ imprisonment was the appropriate disposition of this case [Criminal Case, Doc. 465]. The Court ultimately accepted that agreement and sentenced petitioner to a term of 255 months, consisting of 135 months as to Counts 1, 2, and 4, to be served concurrently, and 120 months as to Count 10, to be served consecutively [Criminal Case, Doc. 761].

Petitioner appealed [Criminal Case, Doc. 771]. On appeal, his counsel filed a brief and motion to withdraw, pursuant to Anders v. California, 386 U.S. 738 (1967) [Criminal Case, Doc. 890, p. 1]. The Sixth Circuit granted counsel’s motion to withdraw and affirmed petitioner’s convictions and sentence [Id. at 8]. On June 21, 2024, petitioner filed the instant § 2255 motion [Docs. 1, 2]. Petitioner

raises one ground for relief, specifically, that his counsel was ineffective for failing to challenge the § 924(c) charge when it was based on an inchoate offense, conspiracy, as the predicate drug offense [Id.]. 2 II. Legal Standard The Court must vacate, set aside, or correct a prisoner’s sentence if it finds that “the judgment was rendered without jurisdiction, or that the sentence imposed was not

authorized by law or otherwise open to collateral attack, or that there has been such a denial or infringement of the constitutional rights of the prisoner as to render the judgment vulnerable to collateral attack . . . .” 28 U.S.C. § 2255. To obtain relief under § 2255 because of a constitutional error, the error must be one of “constitutional magnitude which had a substantial and injurious effect or influence on the proceedings.” Watson v. United

States, 165 F.3d 486, 488 (6th Cir. 1999) (citing Brecht v. Abrahamson, 507 U.S. 619, 637 (1993)). A § 2255 petitioner has the burden of proving that he is entitled to relief by a preponderance of the evidence, Pough v. United States, 442 F.3d 959, 964 (6th Cir. 2006), and must clear a significantly higher hurdle than would exist on direct appeal. United States v. Frady, 456 U.S. 152, 166 (1982).

III. Analysis Claims of ineffective assistance of counsel are cognizable under § 2255. Massaro v. United States, 538 U.S. 500, 508–09 (2003). A petitioner alleging ineffective assistance of counsel must satisfy the two-part test set forth in Strickland v. Washington, 466 U.S. 668, 687 (1987). First, he must identify specific acts or omissions to prove that counsel’s

performance was deficient and that counsel did not provide “reasonably effective assistance,” Strickland, 466 U.S. at 687, as measured by “prevailing professional norms.” Rompilla v. Beard, 545 U.S. 374, 380 (2005). Counsel is presumed to have provided 3 effective assistance, and petitioner bears the burden of showing otherwise. Mason v. Mitchell, 320 F.3d 604, 616–17 (6th Cir. 2003); see also Strickland, 466 U.S. at 689 (providing that a reviewing court “must indulge a strong presumption that counsel’s

conduct falls within the wide range of reasonable professional assistance”). Second, a petitioner must also establish “a reasonable probability that, but for [counsel’s acts or omissions], the result of the proceedings would have been different.” Strickland, 466 U.S. at 694. “An error by counsel, even if professionally unreasonable, does not warrant setting aside the judgment of a criminal proceeding if the error had no

effect on the judgment.” Id. at 691. Because a petitioner “must satisfy both prongs of Strickland to obtain relief on an ineffectiveness claim, the inability to prove either one of the prongs—regardless of which one—relieves the reviewing court of any duty to consider the other.” Nichols v. United States, 563 F.3d 240, 249 (6th Cir. 2009) (en banc); accord Strickland, 466 U.S. at 697.

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Related

Anders v. California
386 U.S. 738 (Supreme Court, 1967)
United States v. Frady
456 U.S. 152 (Supreme Court, 1982)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Brecht v. Abrahamson
507 U.S. 619 (Supreme Court, 1993)
Massaro v. United States
538 U.S. 500 (Supreme Court, 2003)
George C. Watson v. United States
165 F.3d 486 (Sixth Circuit, 1999)
Ricardo Arredondo v. United States
178 F.3d 778 (Sixth Circuit, 1999)
Tyrone K. Harris v. United States
204 F.3d 681 (Sixth Circuit, 2000)
Maurice A. Mason v. Betty Mitchell
320 F.3d 604 (Sixth Circuit, 2003)
Lance Pough v. United States
442 F.3d 959 (Sixth Circuit, 2006)
Rompilla v. Beard
545 U.S. 374 (Supreme Court, 2005)
Nichols v. United States
563 F.3d 240 (Sixth Circuit, 2009)
Thomas Richardson v. Carmen Palmer
941 F.3d 838 (Sixth Circuit, 2019)

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Bluebook (online)
Whittenberg v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/whittenberg-v-united-states-tned-2025.