United States v. James
2:15-cr-00025
E.D. Tenn.Aug 29, 2019Background
- Quincy Dee James pled guilty under a Rule 11(c)(1)(C) agreement to possession with intent to distribute 112–196 grams of crack cocaine; parties agreed to a 180‑month sentence.
- Facts in the plea agreement and PSR: recorded controlled buys (Feb and Aug 2014), execution of a search warrant in Oct 2014 that yielded ~89.99g crack and other indicia; Petitioner admitted possession and two prior Tennessee felony drug convictions (2008).
- PSR classified James as a career offender (USSG §4B1.1) based on the prior convictions, producing an offense level 31 and Guideline range 188–235 months; court accepted the 180‑month agreed sentence on Oct 20, 2015.
- James filed a pro se §2255 motion (Oct 28, 2016) asserting ineffective assistance of counsel in four respects and later sought to amend/supplement with a new claim (filed Apr 3, 2017).
- The court denied the motion to supplement (procedural defects), found the proposed amendment was actually an untimely new claim not relating back under Rule 15(c) and barred by §2255(f), and denied the §2255 motion on the merits for being conclusory and failing Strickland prejudice/performance showings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether to allow a time‑open motion to supplement record | James sought leave to file a memorandum later without particulars | Govt opposed; court noted Rule 7(b) requires particularity | Denied — motion too skeletal and open‑ended |
| Whether the April 2017 filing was a supplement or an amendment and whether it was timely | James characterized it as supplement/amend raising counsel’s failure to challenge career‑offender predicate under §4B1.2(b) | Govt: it is a new claim, subject to AEDPA 1‑year limit; not timely and does not relate back | Treated as amendment; denied as untimely under §2255(f)(1) and not saved by (f)(3) or equitable tolling |
| Ineffective assistance for failing to move to suppress search warrant | Counsel failed to challenge probable cause for the warrant | Govt: claim is conclusory; record supports probable cause (recorded buys, third‑party statements); suppression motion likely meritless | Denied — claim conclusory; no deficient performance or prejudice shown |
| Various other ineffective assistance claims (drug‑quantity objection; failure to invoke Johnson against Guidelines; failure to explain plea rights) | Counsel failed to object to quantity, to raise Johnson vagueness on Guidelines, and failed to explain plea waivers/rights | Govt: quantity was stipulated; Beckles forecloses Johnson challenge to Sentencing Guidelines; plea colloquy cured any misunderstanding; merits lacking | Denied — all claims meritless or conclusory; no Strickland prejudice or performance established |
Key Cases Cited
- Johnson v. United States, 135 S. Ct. 2551 (2015) (ACCA residual‑clause vagueness decision)
- Beckles v. United States, 137 S. Ct. 886 (2017) (Sentencing Guidelines’ residual clause not subject to vagueness challenge)
- Hill v. Lockhart, 474 U.S. 52 (1985) (prejudice standard for ineffective assistance in plea context)
- Strickland v. Washington, 466 U.S. 668 (1984) (two‑prong ineffective assistance test)
- Kimmelman v. Morrison, 477 U.S. 365 (1986) (ineffective assistance in failing to litigate Fourth Amendment claims)
- United States v. Leon, 468 U.S. 897 (1984) (deference to magistrate probable‑cause determinations)
- Mayle v. Felix, 545 U.S. 644 (2005) (relation‑back standard for amended habeas claims)
- Molina‑Martinez v. United States, 136 S. Ct. 1338 (2016) (effect of Guideline calculation errors on sentencing review)