Meachem v. United States

Background

Tyrone Meachem filed a petition under 28 U.S.C. § 2255, a procedure allowing a federal prisoner to challenge a conviction or sentence, seeking relief from his conviction under 18 U.S.C. § 924(c)(1)(A). That statute prohibits using or carrying a firearm during and in relation to a qualifying drug-trafficking crime or crime of violence, or possessing a firearm in furtherance of such a crime. Meachem also appeared to claim that his lawyer had provided ineffective assistance.

Meachem had pleaded guilty to conspiracy to commit Hobbs Act robbery and to the firearm offense. During his plea hearing, he admitted that he and others agreed to rob someone of illegal drugs, that the plan involved violence or threatened violence, and that he knew another person had a gun that would be used if necessary. He was sentenced to time served on the robbery-conspiracy count and 60 months on the firearm count, to run consecutively.

Claims and Governing Decision

Meachem later argued that his firearm conviction could not stand under United States v. Davis. Davis held that the definition of “crime of violence” in 18 U.S.C. § 924(c)(3)(B) was unconstitutionally vague. Meachem argued that conspiracy to commit Hobbs Act robbery could no longer serve as the crime-of-violence predicate for his firearm conviction.

The Government argued that the narcotics conspiracy charged in another count supplied an independent drug-trafficking predicate for the firearm conviction. The court examined the plea transcript, however, and found that Meachem admitted only that he intended to rob someone of drugs. He did not admit to an agreement to distribute the drugs that would be stolen. The court therefore concluded that the firearm conviction could not be preserved on the basis of a drug-trafficking predicate.

Rulings

The court denied Meachem’s challenge to his Hobbs Act robbery-conspiracy conviction. It found that his factual statements during the plea hearing established that he agreed with others to commit the robbery and knew that a gun would be used. The court also found no basis to conclude that the plea was insufficient or that counsel was constitutionally ineffective.

The court granted Meachem’s Section 2255 petition to the extent it challenged the firearm conviction. Relying on Davis, the court ruled that the Section 924(c)(1)(A) conviction could not stand because the Hobbs Act robbery conspiracy could no longer qualify as a “crime of violence” under the invalidated definition. The court vacated that conviction and ordered resentencing.

The court separately addressed Meachem’s May 28, 2020 filing labeled a “writ of mandamus.” A mandamus petition asks a higher court to order a lower court or official to take a required action. The district court ruled that the petition should have been filed in the U.S. Court of Appeals for the Second Circuit and transferred it there for lack of jurisdiction. The court directed the Clerk to close the two civil cases and scheduled Meachem’s resentencing for August 17, 2020.