United States v. Cornell
1:15-cr-00012
S.D. OhioJul 16, 2024Background
- Christopher Lee Cornell (a/k/a Raheel Mahrus Ubaydah) was convicted of attempted murder of government employees, possession of a firearm during a crime of violence, and attempted material support to a foreign terrorist organization.
- Cornell filed a Motion to Amend the Judgment under Fed. R. Civ. P. 59(e) after his initial motion to vacate sentence under 28 U.S.C. § 2255 was denied.
- The court treated the post-judgment motion as referred to the Magistrate Judge for a report and recommendations.
- Cornell’s objections to the Magistrate Judge's decision largely reiterated prior arguments and did not specifically address findings or legal conclusions in the report.
- The court reviewed the objections de novo, addressing the procedural handling, authority of the Magistrate Judge, claim of ineffective counsel, and validity of the guilty plea.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Leave to Amend Judgment | Proposed claims are futile, pleading deficiencies; not qualifying under Rule 59(e) | Court failed to construe pro se filings liberally; should allow amendment to raise new grounds | Amendment would be futile; no clear error in denying leave; proper construction of filings |
| Magistrate Judge Authority | Magistrate had authority under § 636(b); amendments are non-dispositive | Magistrate exceeded authority by denying based on futility, which is dispositive | Magistrate’s actions proper; denial of amendment is non-dispositive |
| Ineffective Assistance of Counsel | Counsel acted reasonably; pursued competency examination | Counsel failed to pursue incompetency and entrapment defenses; forced guilty plea | No error; counsel’s actions appropriate, no evidence of forced plea |
| Voluntariness of Guilty Plea | Plea was knowing and voluntary; proper Rule 11 colloquy | Defendant was actually innocent; plea not fully informed | Plea valid; no new evidence of innocence; waiver of appeal |
Key Cases Cited
- Brady v. United States, 397 U.S. 742 (guilty plea must be voluntary and intelligent under totality of circumstances)
- Boykin v. Alabama, 395 U.S. 238 (guilty pleas must be knowingly and voluntarily made)
- Herrera v. Collins, 506 U.S. 390 (actual innocence alone not a ground for habeas relief)
- Bousley v. United States, 523 U.S. 614 (collateral attack on guilty plea's voluntariness must first be raised on direct review)
- United States v. Broce, 488 U.S. 563 (guilty plea admits guilt of substantive crime)