United States v. Robinson(TV3)
3:22-cr-00084
| E.D. Tenn. | Jun 30, 2025Background
- Gregory Lee Farley pled guilty to conspiracy to distribute methamphetamine in violation of federal law.
- After pleading guilty, Farley filed multiple pro se motions, including allegations of evidence tampering and ineffective assistance of counsel, but later withdrew those motions while affirming he wished to keep his counsel.
- Farley was sentenced to 40 months’ imprisonment and three years of supervised release.
- He filed, then voluntarily dismissed, a direct appeal. A subsequent appeal was dismissed as untimely by the Sixth Circuit, and his petition for rehearing was denied.
- Farley then filed a motion under 28 U.S.C. § 2255, again alleging evidence tampering, perjury, ineffective assistance, and prosecutorial misconduct, and requested appointed counsel.
- The court decided the § 2255 motion based on the record without holding an evidentiary hearing.
Issues
| Issue | Farley's Argument | Government's Argument | Held |
|---|---|---|---|
| Appointment of Counsel | Counsel should be appointed due to complex issues | No exceptional circumstances to require counsel | Denied; no right to counsel or exceptional circumstances |
| Procedural Default | Challenges to drug weight evidence should be heard | Claims are defaulted; not raised on direct appeal | Denied; claims procedurally defaulted |
| Actual Innocence Exception | Evidence disputes show innocence, not just legal issues | Only factual innocence, not legal insufficiency, qualifies | Denied; insufficient for actual innocence exception |
| Need for Hearing | Requested hearing on § 2255 motion | No factual issue requiring evidentiary hearing | Denied; record conclusively shows no entitlement to relief |
Key Cases Cited
- Watson v. United States, 165 F.3d 486 (6th Cir. 1999) (constitutional error must have substantial and injurious effect for § 2255 relief)
- Brecht v. Abrahamson, 507 U.S. 619 (1993) (standard for habeas relief requires substantial and injurious effect)
- United States v. Frady, 456 U.S. 152 (1982) (higher burden exists for collateral relief than direct appeal)
- Pennsylvania v. Finley, 481 U.S. 551 (1987) (no constitutional right to counsel on collateral attack)
- Bousley v. United States, 523 U.S. 614 (1998) (actual innocence exception to procedural default requires factual innocence, not legal insufficiency)