Daniels v. United States

PETITIONER: Daniels
RESPONDENT: United States
LOCATION: Medical University of South Carolina

DOCKET NO.: 99-9136
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Ninth Circuit

CITATION: 532 US 374 (2001)
ARGUED: Jan 08, 2001
DECIDED: Apr 25, 2001

ADVOCATES:
G. Michael Tanaka - Los Angeles, California, argued the cause for the petitioner
Michael R. Dreeben - Department of Justice, argued the cause for the respondent

Facts of the case

In 1994, Earthy D. Daniels, Jr., was convicted of being a felon in possession of a firearm. Under the Armed Career Criminal Act of 1984 (ACCA), which imposes a mandatory minimum 15-year sentence on anyone convicted of being a felon in possession of a firearm and who has three previous convictions for a violent felony, Daniels' sentence was enhanced. After an unsuccessful appeal, Daniels filed a motion to vacate, set aside, or correct his federal sentence. Daniels argued that his sentence violated the Constitution because it was based in part on two prior convictions that were themselves unconstitutional. The District Court denied the motion. The Court of Appeals affirmed.

Question

May a federal defendant, who has been sentenced under the Armed Career Criminal Act of 1984, challenge his federal sentence through a motion on the ground that his prior convictions were unconstitutionally obtained?

Media for Daniels v. United States

Audio Transcription for Oral Argument - January 08, 2001 in Daniels v. United States

Audio Transcription for Opinion Announcement - April 25, 2001 in Daniels v. United States

The opinions of the Court in two cases will be announced by Justice O’Connor.

Sandra Day O'Connor:

The first case is Daniels versus the United States which comes here on writ of certiorari to the United States Court of Appeals for the Ninth Circuit.

The petitioner Earthy Daniels was convicted in Federal Court of being a felon in possession of a firearm.

Because he had four prior state convictions for violent felonies, his federal sentence was enhanced under the Armed Career Criminal Act of 1984.

After an unsuccessful direct appeal, he filed a motion under 28 U.S.C. Section 2255 seeking to vacate, set aside or correct his federal sentence.

He argued that the enhanced sentence violated the Constitution because it was based in part on two prior state convictions, which were themselves unconstitutional.

Both prior convictions he claimed were based on inadequate guilty pleas and he said one was the product of ineffective assistance of counsel.

The District Court denied the Section 2255 motion in the Court of Appeals for the Ninth Circuit affirmed.

In an opinion filed with the Clerk of the Court today, we affirm that judgment of the Ninth Circuit.

In Custis versus United States, we held that with the sole exception of convictions obtained in violation of the right to counsel, a defendant has no right under the Armed Career Criminal Act or at the Constitution to collaterally attack prior convictions at his federal sentencing proceeding.

The consideration supporting that conclusion ease of administration and the interest in promoting the finality of judgments are equally present and forceful in the context of a petition under Section 2255.

A defendant convicted in State Court may challenge the constitutionality of his conviction on direct appeal, in state postconviction proceedings and in a petition for a writ of habeas corpus under Section 28 2254.

After an enhanced federal sentence has been imposed pursuant to the Armed Career Criminal Act, the defendant may pursue any channels of direct or collateral review still available to challenge prior conviction used to enhance the federal sentence.

If however the prior conviction is no longer open to direct or collateral review because the defendant failed to pursue those remedies while they were available or because he did so unsuccessfully then the defendant is without further recourse.

The presumption of validity that attached to the prior conviction at the time of federal sentencing is conclusive, and the defendant may not collaterally attack his prior conviction through a §2255 motion directed at the enhanced sentence.

So, as in the previous Custis case, we recognized an exception to the rule where the prior conviction was obtained for failure to appoint counsel at all, but we think a contrary rule what effectively permit challenges too stale to be brought in their own right and would sanction an end run around statutes of limitations and other procedural barriers that would preclude the movant from attacking the prior conviction directly.

Because the petitioner here failed to pursue remedies that were otherwise available with respect to his prior state convictions, his Section 2255 motion was properly denied.

Justice Scalia has joined all but Part 2C of the opinion and has filed on opinion concurring in part; Justice Souter has filed a dissenting opinion in which Justices Stevens and Ginsburg have joined; Justice Breyer has filed a dissenting opinion.