Goddard v. United States

Background

Jamel Goddard pleaded guilty to conspiracy to commit sex trafficking of a minor under 18 U.S.C. § 1594(c). The court sentenced him to 292 months in prison followed by 10 years of post-release supervision. The Second Circuit affirmed his conviction.

On April 19, 2022, Goddard submitted a letter asking to “reinstate” his appeal or provide relief under 28 U.S.C. § 2255. He did not file a separate Section 2255 motion. The court stated that, because the conviction had been affirmed on appeal, it could not reinstate the appeal. It nevertheless construed the letter as a Section 2255 motion because it appeared to challenge the legality of his conviction and sentence.

Deadlines and required amendment

The court explained that a federal prisoner generally has one year to file a Section 2255 motion, measured from the latest of four events identified in Section 2255(f), including when the conviction becomes final or when supporting facts could have been discovered through reasonable diligence.

Goddard indicated that he had been detained on Rikers Island for 19 months while answering state criminal charges and had been unable to contact his attorney for this case. He also indicated that he did not know the status of his appeal. The court found that his letter did not sufficiently address whether the motion was timely. It directed him, within 60 days, to show why the motion should not be denied as untimely, including by alleging facts showing that he pursued his rights diligently and that an extraordinary circumstance prevented a timely filing.

The court granted Goddard 60 days to file an amended Section 2255 motion stating all grounds for relief and the supporting facts. It also allowed him 30 days to notify the court in writing if he wanted to withdraw the application. If he did not respond, the letter would remain designated as a Section 2255 motion. The court stated that no response from the government was required at that time.

Ruling and effect

Judge Preska did not decide whether Goddard was entitled to relief from his conviction or sentence. The order instead established how the filing would be treated and required additional information about the claims and timeliness.

The court stated that Goddard had not made a substantial showing that a constitutional right had been denied, so it would not issue a certificate of appealability. It also certified that an appeal from the order would not be taken in good faith and denied fee-free status for an appeal. The Clerk was directed to mail Goddard a copy of the Second Circuit’s September 30, 2019 mandate along with the order.