Williams v. United States

Background

Demetrius Williams, who was proceeding without a lawyer in this petition, pleaded guilty in 2014 to a lesser drug offense and to using and carrying a firearm in relation to a drug-trafficking crime. The court sentenced him to 77 months on the drug count and a consecutive 60-month sentence on the firearm count, for a total of 137 months.

The charges followed Williams’s arrest after an alleged domestic dispute. Police impounded his truck and conducted an inventory search. They found a firearm, ammunition, cash, heroin, cocaine, and crack cocaine. Williams’s trial lawyer challenged the search and requested a hearing, but the parties reached a plea agreement before the hearing occurred. During the guilty-plea proceeding, Williams confirmed that he understood he was giving up his right to challenge the seizure and search evidence.

The United States Court of Appeals for the Second Circuit later granted counsel’s request to withdraw, dismissed the appeal as to the sentence, and summarily affirmed the conviction and special assessment.

Williams’s Claims

Williams filed a motion under 28 U.S.C. § 2255, a procedure allowing a federal prisoner to challenge a sentence on specified constitutional or legal grounds. He argued that his trial lawyer was ineffective for failing to pursue additional challenges to the inventory search and that he should be allowed to withdraw his guilty plea. He claimed the search was unlawful because it was unrelated to the domestic dispute, he did not authorize or witness it, and he did not possess a firearm or threaten the officers.

To prove ineffective assistance, Williams had to show both that his lawyer’s performance was unreasonably deficient and that the deficiency prejudiced him. In the guilty-plea context, prejudice required showing a reasonable probability that he would not have pleaded guilty and would have gone to trial, or that he would have received a better plea agreement.

Inventory Search

The court held that the inventory search was lawful. It explained that police may inventory a vehicle taken into custody without a warrant or probable cause when the search follows standardized procedures and is not conducted in bad faith or solely for investigative purposes. The court found that the officers had legitimate reasons to impound the truck: Williams was being taken into custody, the truck would otherwise be unattended, and the government said it was not legally parked. The officers also allowed Williams to make multiple calls seeking someone who could retrieve the truck before deciding to impound it.

The court rejected Williams’s argument that the search had to be connected to the domestic dispute. It also held that Williams’s consent, presence, or authorization was not required for a valid inventory search. Finally, the court found that Williams did not need to be visibly carrying a firearm or pose a threat to officers for the inventory search to be valid.

Ineffective Assistance and Prejudice

The court concluded that Williams’s lawyer had not performed unreasonably. Counsel had filed multiple challenges to the search and then honored Williams’s decision to accept a plea agreement rather than pursue arguments the court found would have been futile. The court also relied on Williams’s statements during the plea proceeding that he understood the rights he was giving up and was satisfied with counsel’s representation.

The court separately found no prejudice. Because the proposed suppression arguments lacked merit, Williams could not show that pursuing them would have changed the result. The court also noted that he had not provided objective evidence that he would have rejected the plea or obtained a better agreement with different advice.

Hearing and Disposition

The court decided that an evidentiary hearing was unnecessary because the case records conclusively showed that Williams was not entitled to relief. Judge Kenneth M. Karas dismissed the petition. The court did not add a prejudice qualifier to that disposition. It also declined to issue a certificate of appealability, certified that an appeal from the judgment would not be taken in good faith, directed entry of judgment for the United States, and ordered the case closed.