United States v. Stubblefield, 931 F. Supp. 2d 118

Stubblefield pro se §2255 movant alleges ineffective assistance by trial counsel and seeks an evidentiary hearing.
Offenses spanned multiple bank robberies in DC in early 2008, culminating in six counts of bank robbery and one count of attempted bank robbery.
Evidence included eyewitness descriptions of a short, dark-skinned man with facial scarring, matching Stubblefield’s appearance.
Arrest followed a May 12, 2008 stop, flight from officers, and a photograph-assisted identification linked to the robberies.
Authorities later verified the cash trail and the suspect’s identity via fingerprinting and a booking photo used in a photo array.
Judge Kennedy denied suppression motions; trial resulted in a guilty verdict on February 13, 2009; sentencing occurred September 2009.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel was ineffective for failing to file suppression/quash motions	Stubblefield alleges Shaner failed to seek suppression or quash.	Shaner acted reasonably; suppression would not have changed outcome.	No relief; no prejudice shown.
Whether suppression of the booking photo would have altered the verdict	Photographs and identifications would have been suppressed, changing trial.	Probable cause existed; arrest/search lawful.	Probable cause supported arrest; no prejudice.
Whether an evidentiary hearing is required under §2255			Hearing not required; record conclusively shows no relief.

Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (standard for ineffective assistance of counsel; deficiency plus prejudice)
Kimmelman v. Morrison, 477 U.S. 365 (U.S. 1986) (adequacy of counsel; fair trial requires competent representation)
United States v. Wood, 879 F.2d 927 (D.C. Cir. 1989) (prejudice on suppression claims must be shown)
United States v. Davis, 235 F.3d 584 (D.C. Cir. 2000) (reasonableness of stop; Terry stop standards)
United States v. Hensley, 469 U.S. 221 (U.S. 1985) (reasonable suspicion sufficient for investigatory stops)
Illinois v. Gates, 462 U.S. 213 (U.S. 1983) (probable cause requires totality of circumstances)
Beck v. Ohio, 379 U.S. 89 (U.S. 1964) (probable cause standard for arrest)
United States v. Brookhardt, 277 F.3d 558 (D.C. Cir. 2002) (arrest lawful if probable cause for different offense exists)
United States v. Carpenter, 342 F.3d 812 (7th Cir. 2003) (probable cause based on totality; relevant similarities to suspect)
United States v. Gilliam, 167 F.3d 628 (D.C. Cir. 1999) (probable cause based on totality and corroborated descriptors)
United States v. Morrison, 449 U.S. 361 (U.S. 1981) (exclusionary rule not extending to grand juries)
United States v. Blue, 384 U.S. 251 (U.S. 1966) (fruit of illegal arrest may be suppressed but indictment may not be)
Kozinski v. Morrison, 414 U.S. 338 (U.S. 1974) (Calandra cited re grand jury limits)