United States v. Darron Goods
678 F. App'x 151
| 4th Cir. | 2017Background
- Appellant Darron Goods filed a 28 U.S.C. § 2255 motion alleging ineffective assistance of counsel and Brady/Giglio nondisclosure by the Government.
- Goods’ ineffective-assistance claims: (1) counsel failed to call favorable witnesses; (2) counsel failed to seek a limiting instruction about a key witness’s testimony; and (3) the cumulative effect of those omissions undermined convictions and sentence.
- Goods’ fourth claim alleged Government misconduct for failing to disclose material information about a witness (Brady/Giglio), and counsel’s ineffectiveness for not pursuing that information.
- The district court expressly addressed and denied relief on the first two ineffective-assistance claims but did not rule on the Brady/Giglio nondisclosure claim or the related ineffectiveness claim.
- Because not all claims were adjudicated, the Fourth Circuit concluded the district court had not entered a final order and therefore the court lacked appellate jurisdiction. The Fourth Circuit dismissed the appeal and remanded for resolution of the remaining claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether appellate jurisdiction exists over the district court’s § 2255 order | Goods treated the district court’s adverse order as final and appealed | Appellee implicitly treated the order as final (parties did not contest jurisdiction) | No appellate jurisdiction: order was not final because some § 2255 claims were unresolved; appeal dismissed |
| Ineffective assistance — failure to call witnesses | Counsel omitted witnesses who would have bolstered Goods’ defense | Government maintained district court properly rejected the claim | District court denied relief on this claim (court addressed and resolved it) |
| Ineffective assistance — failure to request limiting instruction | Counsel failed to obtain limiting instruction about co-defendant obstruction-related testimony | Government maintained district court properly rejected the claim | District court denied relief on this claim (court addressed and resolved it) |
| Brady/Giglio nondisclosure and related counsel ineffectiveness | Government failed to disclose material information about a witness; counsel ineffective for not pressing for it | Government contended there was no basis or district court pending determination | Not decided by district court; Fourth Circuit remanded for consideration of these unresolved claims |
Key Cases Cited
- United States v. Bullard, 645 F.3d 237 (4th Cir. 2011) (appellate courts have an independent duty to confirm jurisdiction)
- Goode v. Central Virginia Legal Aid Society, Inc., 807 F.3d 619 (4th Cir. 2015) (appellate jurisdiction exists only over final and certain interlocutory/collateral orders)
- Catlin v. United States, 324 U.S. 229 (1945) (definition of a final decision ending the litigation on the merits)
- Robinson v. Parke-Davis & Co., 685 F.2d 912 (4th Cir. 1982) (Rule 54(b) finality principles apply; order disposing of fewer than all claims is not final)
- Porter v. Zook, 803 F.3d 694 (4th Cir. 2015) (no appellate jurisdiction where the district court failed to enter judgment on all claims in collateral attack)
- Brady v. Maryland, 373 U.S. 83 (1963) (prosecution’s obligation to disclose materially exculpatory evidence)
- Giglio v. United States, 405 U.S. 150 (1972) (prosecution must disclose evidence affecting witness credibility)