United States v. Sampson
2011 U.S. Dist. LEXIS 121294
D. Mass.2011Background
- Gary Lee Sampson was charged in 2001 with two counts of carjacking resulting in death under 18 U.S.C. § 2119(3) for killings in MA, NH, and VT, with death as the maximum penalty.
- Sampson pled guilty to the charged offenses; a penalty-phase trial later sentenced him to death on both counts; First Circuit affirmed; Supreme Court denied certiorari in 2008.
- Sampson filed a 28 U.S.C. § 2255 motion asserting ineffective assistance of counsel and related claims; the government moved for summary dismissal under Rule 4(b).
- The court conducted hearings and issued a Memorandum allowing dismissal of several claims while preserving others for further record development or evidentiary hearing.
- Key issues involve whether trial counsel were ineffective for (i) advising pleadings pre-/post-Ring, (ii) failing to present mitigating evidence, (iii) failing to pursue competency issues, and (iv) grand jury conduct and Brady disclosures.
- The court dismissed seven claims on summary dismissal grounds but preserved others for potential relief after further development; a separate order addressed juror misconduct in Claim IV.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Pre-Ring guilty-plea advice | Sampson contends counsel should have advised pleading guilty before Ring to avoid death sentence. | Sampson argues counsel had duty to anticipate Ring and secure life sentence benefits. | Claim dismissed; no duty to predict Ring; failure to advise did not constitute deficient performance. |
| Post-Ring guilty-plea advice | Counsel’s advice to plead guilty after Ring was unreasonable and prejudicial. | Advice fell within reasonable strategy given overwhelming guilt evidence and risks of guilt-phase prejudice. | Claim dismissed; strategy fell within wide range of reasonable professional assistance. |
| Mitigation investigation and evidence | Trial counsel failed to investigate/present substantial mitigation, including brain injury and childhood abuse. | Investigation was reasonable under Strickland; evidence was either not clearly excludable or would not alter outcome. | Claims not summarily dismissed; discovery/evidentiary development warranted to resolve whether prejudice occurred. |
| Competence and competency proceedings | Counsel failed to raise or pursue a competency determination; Sampson may have been incompetent at trial. | Competence claims require showing reasonable probability of outcome; record insufficient to resolve now. | Claim not summarily dismissed; need further development to resolve competency questions. |
Key Cases Cited
- Ring v. Arizona, 536 U.S. 584 (U.S. 2002) (Court held aggravating factors for death penalty must be found by a jury beyond a reasonable doubt)
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (Two-pronged standard for ineffective assistance: deficient performance and prejudice)
- Porter v. McCollum, 130 S. Ct. 447 (U.S. 2010) (Mitigation presentation and investigation influence prejudicial analysis)
- Wiggins v. Smith, 539 U.S. 510 (U.S. 2003) (Constitutional failure to investigate mitigating evidence and prejudice shown)
- Rompilla v. Beard, 545 U.S. 374 (U.S. 2005) (Requiring thorough investigation into mitigating evidence in capital sentencing)
- Owens v. United States, 483 F.3d 48 (1st Cir. 2007) (Remanding for development when § 2255 claims are not conclusively resolvable)
- United States v. Rivera-Figueroa, 149 F.3d 1 (1st Cir. 1998) (Commerce clause jurisdictional element upholding § 2119)