Christopher Stoufflet v. United States
757 F.3d 1236
| 11th Cir. | 2014Background
- Christopher Stoufflet operated an online pharmacy that dispensed >260,000 prescriptions and generated >$75 million; he was indicted in 2006 on drug- and money‑laundering charges.
- A 2008 information charged Stoufflet with drug conspiracy and money laundering; he pleaded guilty in that proceeding and the 2006 indictment counts were dismissed.
- After the plea, the district court ruled the advice‑of‑counsel defense was relevant (treating conspiracy as a specific‑intent crime); Stoufflet moved to withdraw his plea alleging coercion and misunderstanding; the district court denied the motion after a hearing.
- Stoufflet appealed; appointed counsel filed an Anders brief concluding any appeal would be frivolous; Stoufflet filed a pro se response arguing his plea was involuntary because he misunderstood conspiracy’s mental‑state element; the Eleventh Circuit granted counsel’s Anders motion and affirmed.
- Stoufflet then filed a 28 U.S.C. § 2255 motion asserting his guilty plea was involuntary; the district court denied relief as procedurally barred because the voluntariness claim had been raised and rejected on direct appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Stoufflet may relitigate voluntariness of his guilty plea in a §2255 motion after raising it in response to appointed counsel's Anders brief on direct appeal | Stoufflet: his pro se Anders response did not trigger preclusion because the posture pitted appointed counsel against him; also argued intervening change in law (Tobin) and manifest injustice | Government: the voluntariness claim was raised and rejected on direct appeal and thus is procedurally barred from collateral attack under §2255 | Court: Procedural bar applies—Stoufflet is precluded from relitigating plea voluntariness in §2255 because he presented and lost that issue on direct appeal; Tobin did not change the law retroactively nor warrant reconsideration |
Key Cases Cited
- Anders v. California, 386 U.S. 738 (approved procedure for appointed counsel to seek withdrawal when appeal is frivolous)
- Nyhuis v. United States, 211 F.3d 1340 (11th Cir. 2000) (issues decided on direct appeal cannot be relitigated in §2255)
- Mills v. United States, 36 F.3d 1052 (11th Cir. 1994) (prior disposition on direct appeal generally precludes collateral review)
- Rowan v. United States, 663 F.2d 1034 (11th Cir. 1981) (no requirement to reconsider §2255 claims already decided on direct appeal)
- Johnson v. United States, 615 F.2d 1125 (5th Cir. 1980) (issues determined on direct appeal need not be reconsidered on §2255)
- Buckelew v. United States, 575 F.2d 515 (5th Cir. 1978) (same)
- Sanders v. United States, 373 U.S. 1 (discusses limits on successive §2255 motions and relitigation)
- Westbrook v. Zant, 743 F.2d 764 (11th Cir. 1984) (collateral-attack considerations for repeat petitions)
- Castro v. United States, 540 U.S. 375 (2003) (law‑of‑the‑case not an insurmountable obstacle to collateral relief; distinguishes final-judgment context)
- Hill v. United States, 368 U.S. 424 (1962) (§2255 relief limited to constitutional errors or miscarriages of justice)
- Tobin v. United States, 676 F.3d 1264 (11th Cir. 2012) (clarified willfulness requirement for drug conspiracy; court held it did not change governing law retroactively)
- Rozier v. United States, 701 F.3d 681 (11th Cir. 2012) (discusses limits on reconsidering prior rulings in collateral review)
- Thomas v. United States, 572 F.3d 1300 (11th Cir. 2009) (standards for §2255 review)
- White v. United States, 371 F.3d 900 (7th Cir. 2004) (an issue raised in a pro se response to an Anders brief is nonetheless considered presented)