United States v. Anton Lemar Dames
697 F. App'x 648
11th Cir.2017Background
- Anton Dames filed three post-conviction motions seeking production of Brady material and witness statements and alleging multiple constitutional violations related to his arrest, prosecution, and trial counsel’s conduct.
- His claims included: nondisclosure of Brady evidence; Fourth, Fifth, and Sixth Amendment violations from wrongful arrest and prosecution; Confrontation Clause claim for failure to call a confidential informant; and conflicts/conspiracy involving his trial attorney and the informant.
- The district court treated the filings as motions challenging his sentence and dismissed them for lack of jurisdiction as successive § 2255 motions.
- Dames previously filed a § 2255 motion in 2014 and did not obtain the required appellate-court certification to file a successive § 2255 motion under 28 U.S.C. § 2244(b)(3)(A).
- The Eleventh Circuit reviews jurisdictional questions de novo and requires the movant to establish federal subject-matter jurisdiction. The court agreed that § 2255 is the appropriate vehicle for these claims but was unavailable because Dames had not obtained permission to file a successive motion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Proper procedural vehicle for claims (jurisdiction) | Dames sought discovery and relief via post-conviction motions and sought production of Brady material and other remedies | Gov't argued claims must be pursued under § 2255 and Dames already filed a prior § 2255, so a successive motion needs appellate permission | Court: Claims are properly raised under § 2255 but Dames did not obtain required certification; district court lacked jurisdiction over unauthorized successive § 2255 motions |
| Request for production of documents | Dames requested production of Brady and witness statements | Gov't: no jurisdictional vehicle presented for discovery; seizure of remedy into § 2255 framework | Court: No jurisdictional basis offered for document production; request not entertained |
| Challenge to sentence and conviction (successive attack) | Dames challenged constitutionality of arrest, prosecution, counsel, and evidentiary issues | Gov't: These are collateral attacks on sentence requiring § 2255 and appellate authorization for successive petitions | Court: Motion is an unauthorized successive § 2255; district court correctly dismissed for lack of jurisdiction |
| Confrontation Clause / Brady / counsel misconduct claims | Dames alleged failure to call informant, withheld Brady evidence, and counsel conspiracy/conflict | Gov't: Substantive merits not reached because procedural jurisdiction lacking; claims must be in authorized § 2255 | Court: Did not reach merits; dismissed for lack of jurisdiction as successive § 2255 |
Key Cases Cited
- Williams v. Chatman, 510 F.3d 1290 (11th Cir.) (standard: de novo review of jurisdictional questions)
- United States v. Al-Arian, 514 F.3d 1184 (11th Cir.) (appellate courts must examine subject-matter jurisdiction)
- Sweet Pea Marine, Ltd. v. APJ Marine, Inc., 411 F.3d 1242 (11th Cir.) (burden of establishing federal subject-matter jurisdiction rests with the claimant)
- Farris v. United States, 333 F.3d 1211 (11th Cir.) (district court lacks jurisdiction to entertain unauthorized successive § 2255 motions)
- Brady v. Maryland, 373 U.S. 83 (U.S.) (obligation to disclose exculpatory evidence)