Wooten v. Cauley
2012 U.S. App. LEXIS 7351
6th Cir.2012Background
- Wooten operated Beck's Wheels, buying and selling stolen auto parts and engaging in related automobile services.
- He and associates cash daily proceeds from stolen goods and used cash to acquire more inventory; some items were shipped interstate to Alabama and California.
- In 2000, Wooten was convicted by a federal jury of conspiracy to transport stolen goods, conspiracy to launder money, interstate transportation of stolen goods, aiding and abetting, structuring transactions, and money laundering (>$2 million).
- He was sentenced to 188 months in prison; his direct appeals and §2255 motions were unsuccessful, and he did not obtain permission for successive §2255 motions.
- Wooten then filed a §2241 habeas petition arguing he could rely on the Santos decision to test the legality of his detention via the §2255 savings clause; the district court dismissed as time-barred and later denied merits, ruling Santos not retroactive for collateral review.
- The Sixth Circuit affirmed, holding the §2241 petition was not time-barred and that Wooten failed to prove actual innocence under Santos; thus no jurisdiction to grant relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the §2241 petition is time-barred | Wooten relied on Santos to invoke the savings clause. | District court held Santos-based claim time-barred under §2255(f). | Not time-barred; savings clause jurisdiction proper. |
| Whether Santos retroactively applies on collateral review | Santos should apply retroactively to test detention under the savings clause. | Retroactivity not yet established or addressed by Santos. | Santos retroactive on collateral review. |
| Whether Santos' definition of proceeds as profits applies to Wooten’s conviction | Proceeds defined as profits would undermine his money-laundering conviction. | Even assuming Santos' profits definition, it does not automatically merge with §2314 in this case. | Santos applies retroactively but does not render §1956 conviction invalid here. |
| Whether Wooten demonstrates actual innocence to trigger the savings clause | Actual innocence via Santos would permit §2241 relief. | No adequate innocence showing; Santos does not apply to his circumstances to prove innocence. | Wooten failed to establish actual innocence; no relief under the savings clause. |
Key Cases Cited
- Santos v. United States, 553 U.S. 507 (Supreme Court 2008) (defines proceeds as profits in certain money-laundering contexts; retroactivity on collateral review discussed)
- United States v. Kratt, 579 F.3d 558 (6th Cir. 2009) (discusses merger concerns between predicate offenses and money laundering)
- United States v. Crosgrove, 637 F.3d 646 (6th Cir. 2011) (merger analysis in money laundering cases)
- Payton v. United States, 437 Fed.Appx. 241 (4th Cir. 2011) (merger where actual financial transaction is not an element of predicate offense)
- United States v. Halstead, 634 F.3d 270 (4th Cir. 2011) (retroactivity of Santos for collateral review affirmed)
- United States v. Moreland, 622 F.3d 1147 (9th Cir. 2010) (statutory interpretation of proceeds and retroactivity context)
- United States v. Peterman, 249 F.3d 458 (6th Cir. 2001) (savings clause doctrine governing §2241 relief via §2255 ineffectiveness)
- Charles v. Chandler, 180 F.3d 753 (6th Cir. 1999) (savings clause jurisdiction standard and actual innocence linkage)
- Teague v. Lane, 489 U.S. 288 (1989) (retroactivity framework for new constitutional rules)