Christopher Shawn Linton v. United States
712 F. App'x 920
11th Cir.2017Background
- Christopher Shawn Linton pleaded guilty to multiple fraud and money-laundering offenses and was sentenced to 71 months; the district court ordered placement in a facility able to address his mental-health needs.
- Linton provided his lawyer with a list of treating physicians and said he was bipolar; counsel submitted a letter from Dr. Steve Bonner stating Linton "had been diagnosed with bipolar disorder," but did not present or secure other medical records (e.g., Dr. Narithookil S. Xavier).
- The presentence report listed depression, bipolar disorder, and two prior suicide attempts; the district court treated those facts as established for sentencing but said it was "not convinced" Linton actually had bipolar disorder.
- On direct appeal Linton raised ineffective-assistance claims; this Court held the record permitted resolution and affirmed, concluding the district court accounted for Linton’s mental-health issues when fashioning sentence. United States v. Linton, 601 F. App’x 914.
- Linton filed a 28 U.S.C. § 2255 motion alleging (1) counsel failed to object to the district court’s treatment of Dr. Bonner’s letter and (2) counsel failed to investigate/present medical records establishing bipolar disorder. The district court dismissed both as barred; this Court granted a COA on whether the investigation claim was procedurally defaulted.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether failure-to-investigate ineffective-assistance claim was procedurally defaulted | Linton: claim required factual development (medical records not in record) and was unavailable on direct appeal | Government: claim was available on direct appeal and thus defaulted | Not defaulted — evidence not in the record, so claim was not available on direct appeal |
| Whether counsel’s failure to investigate prejudiced Linton under Strickland | Linton: had counsel obtained records proving bipolar disorder, there is reasonable probability of a lower sentence | Government: district court already accounted for mental-health issues; no reasonable probability of different result | No prejudice — district court considered mental-health factors; Linton cannot show reasonable probability of different sentence |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (1984) (two-prong ineffective-assistance test: performance and prejudice)
- McKay v. United States, 657 F.3d 1190 (11th Cir. 2011) (standard of review for § 2255 and procedural-default principles)
- Mills v. United States, 36 F.3d 1052 (11th Cir. 1994) (issue is "available" on direct appeal if merits can be reviewed without further factual development)
- Stoufflet v. United States, 757 F.3d 1236 (11th Cir. 2014) (claims raised and rejected on direct appeal are barred in § 2255)
- Osley v. United States, 751 F.3d 1214 (11th Cir. 2014) (ineffective-assistance claims are mixed questions reviewed de novo; Strickland prejudice standard)
- Spencer v. Sec'y, Dep't of Corr., 609 F.3d 1170 (11th Cir. 2010) (review of procedural bars in habeas context)
- LeCroy v. United States, 739 F.3d 1297 (11th Cir. 2014) (appellate court may affirm on any record-supported basis)
- United States v. Linton, [citation="601 F. App'x 914"] (11th Cir. 2015) (direct-appeal decision rejecting Linton’s objection argument because district court accounted for mental-health issues)
