Stanley v. United States

Summary

The United States District Court for the District of Maryland denied Randolph Stanley’s motion under 28 U.S.C. § 2255 to vacate, set aside, or correct his sentence. The court rejected his ineffective-assistance claims concerning factual errors, the loss and restitution amounts, and the presentation of family circumstances at sentencing. The court also declined to issue a certificate of appealability.

Holdings

1. Counsel was not ineffective for failing to contest facts that Stanley had repeatedly admitted in the plea agreement, stipulation of facts, and sworn guilty-plea colloquy, including the loss amount, restitution basis, and managerial role enhancement.
2. Counsel was not ineffective for failing to argue that the Guidelines loss amount should be limited to actual loss because the stipulated actual loss exceeded $5.6 million and would not have changed the Guidelines offense level.
3. Counsel's performance was not deficient, and Stanley could not establish prejudice, where counsel and the presentence report presented substantial information about Stanley's wife, children, disabled brother, and deceased father, and counsel argued the impact of imprisonment on his family.
4. No evidentiary hearing was required because the existing record resolved the claims without the need to resolve disputed facts or make credibility determinations.
5. Stanley was not entitled to a certificate of appealability because he failed to make a substantial showing of the denial of a constitutional right and reasonable jurists would not find the court's assessment debatable or wrong.

Questions Presented

1. Whether Stanley received ineffective assistance of counsel because counsel failed to object to or correct alleged factual errors concerning the loss amount, restitution amount, and Stanley's managerial role.
2. Whether counsel was ineffective for failing to negotiate or contest the loss and restitution amounts on the ground that the Guidelines loss amount should have been based only on actual loss.
3. Whether counsel was ineffective for failing to present additional mitigating evidence concerning Stanley's family circumstances at sentencing.
4. Whether Stanley was entitled to an evidentiary hearing on his § 2255 claims.
5. Whether Stanley was entitled to a certificate of appealability.

Disposition

dismissed