Young v. United States

Summary

The United States District Court for the Southern District of Illinois denied Dusty Young’s motion under 28 U.S.C. § 2255 to vacate his conviction and sentence for participating in a methamphetamine distribution conspiracy. The court held that the motion was untimely and that Young had not established entitlement to equitable tolling. The court further concluded that his plea-agreement waiver barred most claims and that his ineffective-assistance-of-counsel claims failed on the merits.

Holdings

1. Young's § 2255 motion was untimely because his conviction became final on January 2, 2020, making January 2, 2021 the limitations deadline, while he filed on October 24, 2022.
2. Young was not entitled to equitable tolling because he failed to show reasonable diligence throughout the limitations period and an extraordinary circumstance that prevented timely filing.
3. The knowing and voluntary plea-agreement waiver barred Young's non-ineffective-assistance claims because those claims fell within the waiver and no applicable exception was established.
4. Young failed to establish ineffective assistance because counsel was not deficient for failing to challenge a nonexistent § 851 enhancement, Ruth foreclosed his career-offender argument, and he showed neither deficient performance nor prejudice from the plea waiver.
5. A certificate of appealability was denied because reasonable jurists would not debate the court's conclusions that the claims were untimely and meritless.

Questions Presented

1. Whether Young's § 2255 motion was timely under 28 U.S.C. § 2255(f).
2. Whether Young established grounds for equitable tolling based on prison lockdowns, restricted law-library access, COVID-19 protocols, and alleged cooperation with the government.
3. Whether the plea agreement's waiver barred Young's non-ineffective-assistance claims.
4. Whether trial counsel rendered ineffective assistance by failing to challenge an alleged § 851 enhancement, the career-offender designation, or the plea agreement's appellate and collateral-attack waiver.
5. Whether Young was entitled to a certificate of appealability.

Disposition

dismissed